Henry v. Dalton
Rhode Island Supreme Court
151 A.2d 362 (1959)
The Henrys (plaintiffs) and the Daltons (defendants) were neighbors. In 1938, the Henrys wanted to build a garage and got the Daltons' oral permission to share use of a driveway across both properties; the Henrys then filled in their land and built the garage, and both families used the shared driveway without incident for nearly two decades. When the Henrys later tried to sell their home, they asked the Daltons to sign a written easement; Mr. Dalton refused and died shortly after, and the relationship with Mrs. Dalton grew strained. The Henrys sued, arguing the oral license had become an irrevocable easement because they had changed their position in reliance on it by improving their property.
Whether an oral license to use property, containing no time limit, remains revocable even though the licensee spent money in reliance on that license.