Williams Island Country Club, Inc. v. San Simeon at the California Club, Ltd.

Sky Lake once owned both a golf course and an adjacent development tract with an entry strip; a paved golf-cart path crossed the entry strip between the 13th and 14th holes, and there was no other safe route. Sky Lake sold the development tract and entry strip to a Peisach entity, with a contract promising reasonable golf-cart easements that were never formally granted. Williams Island Country Club (Williams) (plaintiff) bought the golf course and was told it had an easement across the entry strip; Peisach later sold the entry strip to San Simeon (defendant), which knew of the claimed path easement. When the parties could not agree, San Simeon bulldozed and blocked the path, and Williams sued for a declaration of an easement by implication and a preliminary injunction, which the trial court denied.

Whether an easement by implication arises where land was originally under one owner, one part was used to benefit another part, and the parcels were then severed, with the use reasonably necessary to the benefited parcel.