Triplett v. Beuckman

Francis Wortman owned an island surrounded by a lake on all side; Wortman was the executor of Susan Triplett.

Triplett owned the lake circumscribing the island and all the land on the outside of the lake.

In March 1971, Triplett sold the island to the Beuckman couple while keeping a circumference of the island.

The Beuckmans who had purchased the island were granted an easement to cross the circumference of the island, share the lake for recreation, and access the 60-foot wooden bridge connecting the Beuckman island to the Triplett mainland.

Later, the Beuckmans asked about repairs to the bridge; Tripletts answered that the bridge repair was the Beuckmans' problem. The Beuckmans concluded that maybe they had possession of the bridge; thus, the Beuckmans replaced the bridge with a causeway.

Tripletts sued Beuckmans at the Madison County Courthouse seeking injunctive relief to remove the causeway & re-construct the bridge.

The trial court found that the causeway was a reasonable solution to the unusual bridge problem.

In an easement appurtenant, is the dominant estate responsible for maintaining the easement (here, the bridge)?

Tripletts argued that the causeway limited the recreational use of the lake.

Beuckmans argued that there wasn't much water under the bridge when they removed it to construct the causeway.

The dominant estate is responsible for maintaining and repairing the easement for the servient estate.

The Beuckmans shouldn't have totally altered the easement by constructing a causeway. However, it wouldn't be reasonable and equitable to require the Beuckmans to remove the causeway & re-construct the bridge that the Tripletts had refused to repair to begin with. Thus, the case is remanded to the trial court for a balancing test.