Garza v. Grayson

Gadeholt sold one of his two adjacent lots to the Garzas (plaintiffs) without a sewer easement, then sold the second lot to the Leers with a reserved "easement for public utility purposes" over that lot, without explicitly naming the Garzas as beneficiaries. The Leers' property eventually passed to the Graysons (defendants), and the Garzas sued to enforce the easement to install a sewer line across the Graysons' land; the Graysons argued a deed cannot create an easement benefiting a third party who wasn't part of that conveyance. The trial court ruled for the Garzas.