prescriptive easement claim (South Carolina) · Go Syfert
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prescriptive easement claim in South Carolina

13 South Carolina opinions name it 2 courts 1997–2024 2 in the last five years

The cases below were cited by South Carolina courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (13)

CaseFollowedCited
Hartley v. John Wesley United Methodist Churchgreen
scctapp · 2003 · cited in 6 South Carolina opinions naming this issue, 2004–2016
2 sentences

2016Therefore, if a claimant cannot prove the elements of adverse use, then, under the Court of Appeals’ approach, the claimant could establish a prescriptive easement under a claim of right. “[I]n order for a party to earn a prescriptive easement under claim of right he must demonstrate a substantial belief that he had the right to use the [property] based upon the totality of circumstances surrounding his use.” Hartley v. John Wesley United Methodist Church of Johns Island, 355 S.C. 145, 151 , 584 S.E.2d 386, 389 (Ct. App. 2003).

2016Therefore, if a claimant cannot prove the elements of adverse use, then, under the Court of Appeals’ approach, the claimant could establish a prescriptive easement under a claim of right. “[I]n order for a party to earn a prescriptive easement under claim of right he must demonstrate a substantial belief that he had the right to use the [property] based upon the totality of circumstances surrounding his use.” Hartley v. John Wesley United Methodist Church of Johns Island, 355 S.C. 145, 151 , 584 S.E.2d 386, 389 (Ct. App. 2003).

56
Revis v. Barrettgreen
scctapp · 1996 · cited in 5 South Carolina opinions naming this issue, 2003–2016
2 sentences

2016Elec. & Gas Co., 361 S.C. 434, 440-41 , 604 S.E.2d 714, 717 (Ct. App. 2004) (finding respondent established a prescriptive easement under claim of right because it believed it had the right to use the property for the power lines); Revis v. Barrett, 321 S.C. 206, 210 , 467 S.E.2d 460, 462 (Ct. App. 1996) (determining plaintiff established a prescriptive easement to the use of an old road under claim of right based on her belief that she had the right to use the road). 3 .

2016Elec. & Gas Co., 361 S.C. 434, 440-41 , 604 S.E.2d 714, 717 (Ct. App. 2004) (finding respondent established a prescriptive easement under claim of right because it believed it had the right to use the property for the power lines); Revis v. Barrett, 321 S.C. 206, 210 , 467 S.E.2d 460, 462 (Ct. App. 1996) (determining plaintiff established a prescriptive easement to the use of an old road under claim of right based on her belief that she had the right to use the road). 3 .

45
Morrow v. Dychesgreen
scctapp · 1997 · cited in 3 South Carolina opinions naming this issue, 2003–2012
2 sentences

2012Claim of Right A party claiming a prescriptive easement under a claim of right “must demonstrate a substantial belief that he had the right to use the parcel or road based upon the totality of the circumstances surrounding his use.” Hartley v. John Wesley United Methodist Church, 355 S.C. 145, 151, 584 S.E.2d 386, 389 (Ct.App.2003); see Revis v. Barrett, 321 S.C. 206, 209 , 467 S.E.2d 460, 462 (Ct.App.1996) (holding a party’s belief that she had a right to use a road flowed from a claim of right that originated with her parents’ use of the roadway to access the property, and her use of the roa

2012Claim of Right A party claiming a prescriptive easement under a claim of right “must demonstrate a substantial belief that he had the right to use the parcel or road based upon the totality of the circumstances surrounding his use.” Hartley v. John Wesley United Methodist Church, 355 S.C. 145, 151, 584 S.E.2d 386, 389 (Ct.App.2003); see Revis v. Barrett, 321 S.C. 206, 209 , 467 S.E.2d 460, 462 (Ct.App.1996) (holding a party’s belief that she had a right to use a road flowed from a claim of right that originated with her parents’ use of the roadway to access the property, and her use of the roa

33
Loftis v. South Carolina Electric & Gas Co.green
scctapp · 2004 · cited in 2 South Carolina opinions naming this issue, 2005–2016
2 sentences

2016Elec. & Gas Co., 361 S.C. 434, 440-41 , 604 S.E.2d 714, 717 (Ct. App. 2004) (finding respondent established a prescriptive easement under claim of right because it believed it had the right to use the property for the power lines); Revis v. Barrett, 321 S.C. 206, 210 , 467 S.E.2d 460, 462 (Ct. App. 1996) (determining plaintiff established a prescriptive easement to the use of an old road under claim of right based on her belief that she had the right to use the road). 3 .

2016Elec. & Gas Co., 361 S.C. 434, 440-41 , 604 S.E.2d 714, 717 (Ct. App. 2004) (finding respondent established a prescriptive easement under claim of right because it believed it had the right to use the property for the power lines); Revis v. Barrett, 321 S.C. 206, 210 , 467 S.E.2d 460, 462 (Ct. App. 1996) (determining plaintiff established a prescriptive easement to the use of an old road under claim of right based on her belief that she had the right to use the road). 3 .

22
Matthews v. Dennisgreen
scctapp · 2005 · cited in 2 South Carolina opinions naming this issue, 2012–2012
2 sentences

2012Matthews v. Dennis, 365 S.C. 245, 250 , 616 S.E.2d 437, 440 (Ct.App.2005).

2012Matthews v. Dennis, 365 S.C. 245, 250 , 616 S.E.2d 437, 440 (Ct.App.2005).

22
Paine Gayle Properties, LLC v. CSX Transportation, Inc.green
scctapp · 2012 · cited in 2 South Carolina opinions naming this issue, 2013–2015
2 sentences

2013See McCrea v. City of Georgetown, 384 S.C. 328, 332 , 681 S.E.2d 918, 921 (Ct. App. 2009) (noting stipulations are binding on the parties as well as the court); Paine Gayle Properties, LLC v. CSX Transp., Inc., 400 S.C. 568, 585-86 , 735 S.E.2d 528, 537-38 (Ct. App. 2012) (discussing permissive use of the disputed property and finding the granting of permission to use the property defeats a prescriptive easement claim).

2013See McCrea v. City of Georgetown, 384 S.C. 328, 332 , 681 S.E.2d 918, 921 (Ct. App. 2009) (noting stipulations are binding on the parties as well as the court); Paine Gayle Properties, LLC v. CSX Transp., Inc., 400 S.C. 568, 585-86 , 735 S.E.2d 528, 537-38 (Ct. App. 2012) (discussing permissive use of the disputed property and finding the granting of permission to use the property defeats a prescriptive easement claim).

12
Cleland v. Westvaco Corp.green
scctapp · 1993 · cited in 1 South Carolina opinions naming this issue, 2024–2024
2 sentences

2024See Cleland v. Westvaco Corp., 314 S.C. 508, 511 , 431 S.E.2d 264 , 266–67 (Ct. App. 1993) (noting an unsuccessful argument for public rights did not necessarily defeat an individual claim for an easement); see also Nelums v. Cousins, 304 S.C. 306, 308 , 403 S.E.2d 681, 682 (1991) (finding a plaintiff's prescriptive easement claim was asserted independent of use by others).

2024See Cleland v. Westvaco Corp., 314 S.C. 508, 511 , 431 S.E.2d 264 , 266–67 (Ct. App. 1993) (noting an unsuccessful argument for public rights did not necessarily defeat an individual claim for an easement); see also Nelums v. Cousins, 304 S.C. 306, 308 , 403 S.E.2d 681, 682 (1991) (finding a plaintiff's prescriptive easement claim was asserted independent of use by others).

11
Nelums v. Cousinsgreen
scctapp · 1991 · cited in 1 South Carolina opinions naming this issue, 2024–2024
2 sentences

2024See Cleland v. Westvaco Corp., 314 S.C. 508, 511 , 431 S.E.2d 264 , 266–67 (Ct. App. 1993) (noting an unsuccessful argument for public rights did not necessarily defeat an individual claim for an easement); see also Nelums v. Cousins, 304 S.C. 306, 308 , 403 S.E.2d 681, 682 (1991) (finding a plaintiff's prescriptive easement claim was asserted independent of use by others).

2024See Cleland v. Westvaco Corp., 314 S.C. 508, 511 , 431 S.E.2d 264 , 266–67 (Ct. App. 1993) (noting an unsuccessful argument for public rights did not necessarily defeat an individual claim for an easement); see also Nelums v. Cousins, 304 S.C. 306, 308 , 403 S.E.2d 681, 682 (1991) (finding a plaintiff's prescriptive easement claim was asserted independent of use by others).

11
Brasington v. Williamsgreen
· 1927 · cited in 1 South Carolina opinions naming this issue, 2016–2016
2 sentences

2016Williamson is not the only case in which this comma appears after the term "adverse.” For example, in Brasington v. Williams, 143 S.C. 223, 261 , 141 S.E. 375, 387 (1927) (Watts, C.J., dissenting), Poole v. Edwards, 197 S.C. 280, 283 , 15 S.E.2d 349, 350 (1941), and Sanitary & Aseptic Package Co. v. Shealy, 205 S.C. 198, 203 , 31 S.E.2d 253, 255 (1944), this Court cited the Williamson test, with the comma, verbatim.

2016Williamson is not the only case in which this comma appears after the term "adverse.” For example, in Brasington v. Williams, 143 S.C. 223, 261 , 141 S.E. 375, 387 (1927) (Watts, C.J., dissenting), Poole v. Edwards, 197 S.C. 280, 283 , 15 S.E.2d 349, 350 (1941), and Sanitary & Aseptic Package Co. v. Shealy, 205 S.C. 198, 203 , 31 S.E.2d 253, 255 (1944), this Court cited the Williamson test, with the comma, verbatim.

11
Sanitary & Aseptic Package Co. v. Shealygreen
· 1944 · cited in 1 South Carolina opinions naming this issue, 2016–2016
2 sentences

2016Williamson is not the only case in which this comma appears after the term "adverse.” For example, in Brasington v. Williams, 143 S.C. 223, 261 , 141 S.E. 375, 387 (1927) (Watts, C.J., dissenting), Poole v. Edwards, 197 S.C. 280, 283 , 15 S.E.2d 349, 350 (1941), and Sanitary & Aseptic Package Co. v. Shealy, 205 S.C. 198, 203 , 31 S.E.2d 253, 255 (1944), this Court cited the Williamson test, with the comma, verbatim.

2016Williamson is not the only case in which this comma appears after the term "adverse.” For example, in Brasington v. Williams, 143 S.C. 223, 261 , 141 S.E. 375, 387 (1927) (Watts, C.J., dissenting), Poole v. Edwards, 197 S.C. 280, 283 , 15 S.E.2d 349, 350 (1941), and Sanitary & Aseptic Package Co. v. Shealy, 205 S.C. 198, 203 , 31 S.E.2d 253, 255 (1944), this Court cited the Williamson test, with the comma, verbatim.

11
Poole v. Edwardsgreen
sc · 1941 · cited in 1 South Carolina opinions naming this issue, 2016–2016
2 sentences

2016Williamson is not the only case in which this comma appears after the term "adverse.” For example, in Brasington v. Williams, 143 S.C. 223, 261 , 141 S.E. 375, 387 (1927) (Watts, C.J., dissenting), Poole v. Edwards, 197 S.C. 280, 283 , 15 S.E.2d 349, 350 (1941), and Sanitary & Aseptic Package Co. v. Shealy, 205 S.C. 198, 203 , 31 S.E.2d 253, 255 (1944), this Court cited the Williamson test, with the comma, verbatim.

2016Williamson is not the only case in which this comma appears after the term "adverse.” For example, in Brasington v. Williams, 143 S.C. 223, 261 , 141 S.E. 375, 387 (1927) (Watts, C.J., dissenting), Poole v. Edwards, 197 S.C. 280, 283 , 15 S.E.2d 349, 350 (1941), and Sanitary & Aseptic Package Co. v. Shealy, 205 S.C. 198, 203 , 31 S.E.2d 253, 255 (1944), this Court cited the Williamson test, with the comma, verbatim.

11
McCrea v. City of Georgetowngreen
scctapp · 2009 · cited in 1 South Carolina opinions naming this issue, 2013–2013
2 sentences

2013See McCrea v. City of Georgetown, 384 S.C. 328, 332 , 681 S.E.2d 918, 921 (Ct. App. 2009) (noting stipulations are binding on the parties as well as the court); Paine Gayle Properties, LLC v. CSX Transp., Inc., 400 S.C. 568, 585-86 , 735 S.E.2d 528, 537-38 (Ct. App. 2012) (discussing permissive use of the disputed property and finding the granting of permission to use the property defeats a prescriptive easement claim).

2013See McCrea v. City of Georgetown, 384 S.C. 328, 332 , 681 S.E.2d 918, 921 (Ct. App. 2009) (noting stipulations are binding on the parties as well as the court); Paine Gayle Properties, LLC v. CSX Transp., Inc., 400 S.C. 568, 585-86 , 735 S.E.2d 528, 537-38 (Ct. App. 2012) (discussing permissive use of the disputed property and finding the granting of permission to use the property defeats a prescriptive easement claim).

11
Murrells Inlet Corp. v. Wardgreen
scctapp · 2008 · cited in 1 South Carolina opinions naming this issue, 2012–2012
2 sentences

2012Murrells Inlet Corp. v. Ward, 378 S.C. 225, 232 , 662 S.E.2d 452, 455 (Ct.App.2008).

2012Murrells Inlet Corp. v. Ward, 378 S.C. 225, 232 , 662 S.E.2d 452, 455 (Ct.App.2008).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in South Carolina. Read the followed side critically anyway.

Also cited on this issue (3)

CaseCitedYears
Simmons v. Berkeley Electric Cooperative, Inc. green
sc · 2016
2 sentences

2024In Simmons, our supreme court clarified the test to be used in analyzing a prescriptive easement claim. 419 S.C. at 230 , 797 S.E.2d at 391 .

2024In Simmons, our supreme court clarified the test to be used in analyzing a prescriptive easement claim. 419 S.C. at 230 , 797 S.E.2d at 391 .

12024–2024
Eldridge v. City of Greenwood green
scctapp · 1989
2 sentences

1997Co., 85 S.C. 440 , 67 S.E. 546 (1910), the Morrows cite Eldridge v. City of Greenwood, 300 S.C. 369 , 388 S.E.2d 247 (Ct.App.1989), for the proposition that if a railroad ceases to use its right-of-way for railroad purposes and intends to abandon the right-of-way, the property reverts back to its original grantor.

1997Co., 85 S.C. 440 , 67 S.E. 546 (1910), the Morrows cite Eldridge v. City of Greenwood, 300 S.C. 369 , 388 S.E.2d 247 (Ct.App.1989), for the proposition that if a railroad ceases to use its right-of-way for railroad purposes and intends to abandon the right-of-way, the property reverts back to its original grantor.

11997–1997
Blume v. Southern Ry. green
sc · 1910
2 sentences

1997Co., 85 S.C. 440 , 67 S.E. 546 (1910), the Morrows cite Eldridge v. City of Greenwood, 300 S.C. 369 , 388 S.E.2d 247 (Ct.App.1989), for the proposition that if a railroad ceases to use its right-of-way for railroad purposes and intends to abandon the right-of-way, the property reverts back to its original grantor.

1997Co., 85 S.C. 440 , 67 S.E. 546 (1910), the Morrows cite Eldridge v. City of Greenwood, 300 S.C. 369 , 388 S.E.2d 247 (Ct.App.1989), for the proposition that if a railroad ceases to use its right-of-way for railroad purposes and intends to abandon the right-of-way, the property reverts back to its original grantor.

11997–1997

Where else courts name it

NY 16 (1993–2024) MT 15 (1996–2025) SC 13 (1997–2024) CA 11 (2004–2026) ME 11 (2002–2024) OR 10 (2009–2026) UT 8 (1989–2021) ID 7 (1999–2026) WA 6 (2017–2026) CO 6 (2002–2026) RI 6 (2007–2026) IL 5 (1988–2017) OH 5 (2002–2019) TX 4 (2010–2012) MN 4 (2000–2025) MS 4 (1997–2023) IN 4 (2010–2015) NC 4 (1995–2026) CT 4 (1998–2022) MA 4 (2019–2025) GA 3 (2020–2023) NH 3 (1999–2011) WV 3 (2010–2022) NM 3 (2002–2016) MI 2 (2015–2018) NV 2 (2016–2016) SD 2 (2007–2023) TN 2 (2016–2025) MO 2 (2001–2011) PA 2 (2014–2018) WY 2 (2005–2020) NJ 2 (2025–2026) WI 2 (1998–2023) VT 2 (2015–2016)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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