Prescriptive easement time washington state

Washington 10 Aug 1, 2018 An easement is the legal right of a non-owner to use a specific part of . virtually all of Washington States' recorded Adverse Possession cases. We didn't really covet the home; it was simply a suitable • A deed showing easement rights to use the property. Cities, 13 Wn. CHRISTOPHER JACK and PETRA Washington Supreme Court joins courts that reverse the presumption of permissiveness for prescriptive easements. , rural and undeveloped — the law says a prescriptive easement can’t be created. One day he decides to build a garage there because he has no room to add one to his own property. Junior Member. Thus, a negative easement cannot be acquired by prescription because no trespass takes place. Thus, even though a real estate lawyer, technically, has experience in real estate law matters, he or she should have a strong understanding of the various differences in the character and nature of the property Is a prescriptive view easement possible? If a property has been benefited by the open and continuous use of a view over a neighboring property without the permission of the neighboring property's owner for say 10 to 20 years, is it possible that an unrecorded view easement exists? easement occurs when a property owner gives an easement to a dominant estate. 47 Margaret Jane Radin, Time, Possession, and Alienation, 64 Wash. Washington, 260 Conn. " Seattle real estate attorneys, such as those at Dickson Frohlich, PS, are trained to understand the idiosyncrasies of real estate law. of necessity, statutory ways of necessity, and prescriptive easements. Clark, 183 Wn. Jan 1, 2006 suits, adverse possession progressed in the United States as a . 050-. . costs for establishing the prescriptive easement. Easement Laws in Washington State What is an Easement? An Easement is a non-possessory right in real property. This use may result in the loss of certain rights in a portion of the owner’s property, such as a bicycle path, a driveway or a footpath. The United States also appeals the district court's holding that the National . at a time when he is able in law to assert and enforce his rights. Owners of easement may request separation from servient estate for taxation purposes and assessor must comply with request. McDonald, 46 Wn. The decision, while based in part on the usage at the time of the grant of the easement, also took into consideration the relative inconveniences to the parties. Most easements are obtained by an express grant in the form of a deed. Valuable property rights can be lost to neighbors and strangers, seemingly rewarding longtime bad behavior. 36. Such signs -- often found on private roadways -- typically state: "This is a private roadway. In Texas, it is 30 years. State law, which varies by state, defines the time period required to acquire a prescriptive easement. The length of use required for a prescriptive easement varies from state to  In the case of a prescriptive easement based upon historic use, the easement Noland construed Oregon law to state that water rights held abandoned for one Further, failure to use the right-of-way for a period of five years creates a Some consideration is also given to searching federal records in Washington, DC . While disputes in express easements, which are created by written instruments, are easier to mediate; other types of easement disputes are more difficult to resolve. If your land is “open” — i. 2d 135 (1955); 1 Washington State Bar Association, Real Property Deskbook § 13. 2d 669 (1946); State ex rel. Prescriptive Easements – A prescriptive easement arises by adverse and hostile use of the servient estate. When the time passes or the condition occurs, the easement ends. . What is the statutory period for claiming a prescriptive easement in Washington State? period of time they may gain a prescriptive easement. Hebert Moore Elynne Moore’s parcel number 172406-9077, was acquired on May 24, 2012 and includes the fee title to all that property of the abandoned right-of-way that is now subject to an easement for an interim trail and Recently, an interesting issue developed over the applicability of Washington State’s statute regarding waste caused to an easement. Desiderio discuss how New York appellate courts determine whether or not a party is entitled IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON DIVISION ONE ANNE WHYTE, a married person on No. The New World of Prescriptive Easement Cases In their Land Use column, Adam Leitman Bailey and John M. Property Owners: Only you can prevent prescriptive easements. e. cant decisions affecting well-established laws regarding public prescriptive easements in Montana. 04. is an easement given to a utility company by a county or state to run . Washington. encountered by businesses operating in the western United States. The time period that the trespasser must have occupied the land varies by state. To find the time period in your state, see the table below. Re: Easement Rights in Washington State You previously indicated that they're not preventing anybody else from using the easement. 5 Dan, 953 So A permissive easement is simply permission to use the land of another. 3 Id. The title includes a recorded easement that is 10 feet wide, which is not wide enough to get a manufactured home half (14 feet) down the lane. Is a prescriptive view easement possible? If a property has been benefited by the open and continuous use of a view over a neighboring property without the permission of the neighboring property's owner for say 10 to 20 years, is it possible that an unrecorded view easement exists? An easement is implied by necessity when one parcel of land is sold, depriving the other parcel of access to a public road or utility. result in a Washington state case when neighbors treated a driveway as. You don't have much of an argument if you hope to claim that they're interfering with their own rights. A prescriptive easement exists when someone uses a property for a given period of time without the consent or permission of the owner of that property. 610: Easement over public lands subject to common user. L. But, it is also a case which then muddies the water when comparing adverse possession and prescriptive easement. Courts typically refer to the intent of the parties, as well as prior use, to determine the existence of an implied easement. 160). in part, that neither the F-3 easement nor a prescriptive easement theory allowed HHCC to install the 2011 water tank on lot 24. The laws for establishing a prescriptive easement are almost the same as the requirements for establishing adverse possession. The attorney general of the state of Washington is hereby required and authorized to condemn said property interests found to be necessary for the public purposes of the state of Washington, as provided in RCW 79. 6(7) (3d ed. 2 Id. Apr 10, 2018 We compare these times to the Dutch touching New York soil for the first to massive development, the number of prescriptive easement cases  Mar 19, 2018 wash had asserted a claim of prescriptive easement with regard to property has been used in excess of the prescriptive period for many  Apr 22, 2011 Last time we talked about how one of two neighbors (“Joe”) should be careful not to compromise or lose his claim to a prescriptive easement to  Aug 14, 2007 The operative date for the beginning of all time periods for filing the State, State of Connecticut, and may not be repro- duced and claims relating to the alleged prescriptive easement. Prescriptive Easements. Our house was built in 1971 and there exists nowhere in writing that the neighbors have easement rights, but we have let them use it freely. Implied easements are not recorded or explicitly stated until a court decides a dispute, but reflect the practices and customs of use for a property. In some states, the trespasser must have paid taxes on the property during this time period. Rising on the lack of 21 years of continuous use, it never addressed the other elements of adverse possession, namely, that the use must be open, notorious and adverse. Prescriptive easement granted for underground utility lines. Neighbor Loses Right to Use Driveway: Prescriptive Easement Law in Flux? By LeAnne Bremer on March 28, 2014 Posted in Land Use The Gamboas continuously used a driveway located mostly on the property of their neighbors, the Clarks, for over sixteen years. In order to acquire a prescriptive easement over another's property, the under a claim of right to the property; and (6) use for the statutory period of five years. ” Prescriptive easements – To obtain a prescriptive easement in Washington, one property owner must openly, hostilely, and continuously use part of another’s land for 10 years without permission. However, hooking up to an existing sewer easement exclusive and continuous for a certain period of time. The period required to establish a prescriptive easement is 10 years. WA State Part of my property is a 30ft wide private road, approximately 500ft long, that connects with a county road. Man, like a tree in the cleft of a rock, gradually shapes his roots to his surroundings, and when the roots have grown to a certain size, can't be displaced without cutting at his life. HHCC filed a cross motion for summary judgment, arguing in part that either the F-3 easement permitted installation of the 2011 water tank or that it had counties ‑- roads ‑- easements ‑- tax sale of property ‑- county easement reserved A county may reserve county road easements over tax title property which it proposes to sell provided that the right to the easement is first acquired under the county's power of eminent domain or by purchase pursuant to RCW 84. However, hooking up to an existing sewer easement Our Washington State property is landlocked. For example, if a common owner of two parcels sells the parcel away from the public road and retains the front parcel A prescriptive easement is the result of a somewhat complicated legal concept known as adverse possession. Such an easement is called a prescriptive easement. Alternatively, a temporary non-exclusive easement is granted for a specific period of time. The simplest way an easement can terminate is if the time period for the easement’s existence expires. Thus, even though a real estate lawyer, technically, has experience in real estate law matters, he or she should have a strong understanding of the various differences in the character and nature of the property What is the statutory period for claiming a prescriptive easement in Washington State? period of time they may gain a prescriptive easement. 2d at 83. The time period in Washington is 7 years. 310, and upon being furnished with a certified copy of the resolution of the department, describing said property interests found to be necessary for the purposes set forth in RCW A person may acquire an easement by using the servient land a particular way for a long period of time. Re: Washington State Easement Law If after your research you are positive that there is no easement on your property then send all the homeowners a letter revoking their use of your property and gate it off. The parcel of land beside Joe's rural home has been vacant and unused for as long as he can remember — maybe even decades. The Washington Supreme Court has recently struck a chord to promote harmony in our state, and make prescriptive easements tougher to establish in the case of Gamboa v. A prescriptive easement only requires intent to use the property for a specific purpose like an access road. Aug 1, 2017 In other words, the person claiming title by adverse possession is taxes for the applicable property for the five-year possession period. 2d 574, 578, 283 P. In order to be completely certain that a permissive easement will not morph into a prescriptive easement, some landowners erect signs stating the grant of the permissive easement or license. In Washington state, neighbors treated a certain driveway as their own for some forty-odd years, and finally expanded the driveway into a full-blown road. 2nd 38, 348 P. In considering the latter point much weight was placed on the need for convenient and frequent ingress and egress in our modern age. • Whether or not the insurer is comfortable accepting this risk usually comes down to the likelihood of a challenge to the prescriptive easement rights. Attention Property Owners: The owner of real property has the legal burden to protect his or her property against a trespasser trying to establish a prescriptive easement. Prescriptive Easement Requirements The time period for obtaining an easement by adverse possession does not begin to run until the one seeking adverse possession actually trespasses on the land . However, all easements can be limited to a certain period of time, according to their terms. TAXATION ‑- EASEMENTS ‑- SEGREGATION FOR ASSESSMENT PURPOSES. "Prescriptive rights are not favored in the law, since they necessarily work corresponding losses or forfeitures of the rights of other persons. 1997). Intent. 4 Id. Alleged Prescriptive Easement Use In The State Of Washington This is so involved: 1. What Is Prescriptive Easement, Exactly? April 26, 2017 easement prescriptive. An examination of a person's intent is crucial in making the distinction between the two legal doctrines. Easement by Prescription. Easements of limited duration are commonly used to provide temporary access to a dominant estate pending the completion of construction work. The use of the easement must truly be adverse to the rights of the landowner of the property through which the easement is sought and must be without the landowner's permission. To establish a prescriptive easement, it is necessary to show use that has been continuous, uninterrupted, visible and adverse for a period of ten years. Stoebuck, The Law of Adverse Possession in Washington, 35 Wash. A city- or town-owned utility that is located within its street right of way along a nonlimited access state highway within city limits is entitled to utility relocation and/or adjustment cost reimbursement. When that time limit runs out, the easement simply expires and ceases to exist. Jul 1, 2015 The State Supreme Court Confirms Washington is a Neighborly State The Court found that the elements of a prescriptive easement were all the Clarks had “knowledge of such use at the time when [they] would be able at  Sep 4, 2013 Related to adverse possession claims, Washington recognizes 'prescriptive easement' claims. Ohio Court of Appeals Issues “Prescriptive Easement” Decision Addressing “Tacking” and Continuous Use Requirements. The Wallens family owned a cabin on Lummi Island in the state of Washington. 12, at 13-7 (1979). Richman. • A court finding of prescriptive easement rights. easement against the government via adverse possession. Ingress into the easement area by the GRANTEE for any purpose herein shall be made as provided in Section 9 of ARTICLE IV (effective date 10/15/95) or as the parties may otherwise agree. The vacant land doctrine states that use of vacant land by a  Oct 12, 2015 Thus, one can obtain property by adverse possession if one actually possess real property in a visible manner for the statute of limitations  Sep 6, 2017 To establish a prescriptive easement, the person claiming the easement must use another person's land for a period of 10 years and show that  A quick and thorough explanation of Easements in the state of Washington written by the knowledgeable attorneys at the Brink Law Firm. 64. • An easement is the right to use the physical thing that is GRANTEE shall have right of ingress and egress as may from time to time be necessary to insure the proper functioning of the residential septic system. The period of continuous use for a prescriptive easement to become binding is generally between 5 . at 66. A solar easement can only be created by written agreement, but is not authorized to be created by an implied or prescriptive easement (RCW 64. Law of Easements: Legal Issues and Practical Considerations, Other Methods of Creating Easements by Kenneth W. In California, this period is five years. Then state law provides an “open-lands exception” to prescriptive easements. ” 2 In addition, this opinion emphasizes that desultory use (or any use that utilizes a wandering and varied course) will not be considered adverse within the meaning of prescriptive easement doctrine. An easement deed in Washington should specify the terms, duration, and location of the easement. 1 Downing, 100 So. the prescriptive period. Suite 7A An easement is a legal right to use someone else's land for a particular purpose. The user gets an easement by openly, adversely, continuously, and exclusively using the land for a number of years specified by state statute. 2d at 64. Zierman published an article in the Washington State Bar Association’s (WSBA) Bar News titled: A Good-Faith Attack on Land Thieves (See pages 18-20). Other Property Interests Easements are nonpossessory interests in land of another entitling the easement holder to limited use of the other’s land. The time period for obtaining an easement by adverse possession does not begin to run until the one seeking adverse possession actually trespasses on the land. August, 2012 By Ronald L. In other words, even if a prescriptive easement did exist at some time, if the owner of the property shows that the prescriptive easement was not used for at least five years, then the prescriptive easement was extinguished, Property Owners: Only you can prevent prescriptive easements. Prescriptive easements in Washington can be thought of as very similar to the doctine of adverse possession, with the major difference being that adverse possession has to do with "possession" of land and prescriptive easements have to do with "use" of land. Congress - the Other Washington Governor's Website A prescriptive easement is based on the legal doctrine of "adverse possession" which allows someone who is legally a trespasser to acquire property rights if they use another person's property for the statutorily prescribed period of time. We reverse and remand for entry of an order enjoining the use of the easement across parcel A to gain access to a residence any part of which is located on parcel C, or to further the construction of any residence on parcels B or C if the construction activities would require entry onto parcel C. 2. 3d 1214 (2015). In the United States, an easement in gross is used for such needs, especially for permanent rights. Thus, one can obtain property by adverse possession if one actually possess real property in a visible manner for the statute of limitations without regard to proof of lack of permission. Law of Easements: Legal Issues and Practical Considerations in Oregon Law of Easements: Legal Issues and Practical Considerations A. It is essentially a license, which is fully revocable at any time by the property owner. 28. Macomber, Member, Real Property Section, Idaho State Bar. 2d 690, 175 P. That is, everyone except commercial real estate owners who just discovered their ability to use and develop their property has been severely limited without their consent. Professors Bruce and Ely state the prescriptive easement doctrine this way: [G]enerally a person claiming [a prescriptive] easement must show the following: adverse, open and notorious, continuous and uninterrupted use of another's land for the period of prescription. However, prescriptive easements arise when someone uses part of the owner’s property without his or her permission. A perpetual non-exclusive easement renders the land permanently accessible to all those who benefit from the easement.   A prescriptive easement is acquired only by using land in an open and notorious this prevents the acquiring of that easement for any length of time afterward. Washington Law Review. Most state presume such uses are permissive although a growing minority of states presume permission. Many courts apply the same presumption to claims for prescriptive easements. A prescriptive easement can be utilized in any property that is private, not that of any government organization or authority. at 65. Was this easement recorded in favor of  Jul 7, 2015 Washington law has long recognized the creation of easements by use no period of hostile use and the use could not ripen into a prescriptive  owner, and then return to it and count the time that it was abandoned - that wouldn't be adverse possession unless state law requires the trespasser to believe that . The law of prescriptive use does not apply to such cases, but only to those cases where there is a sufficient user which is adverse. I Washington State Bar Ass'n, Real Property Deskbook § 10. 506, 577  Mar 11, 2010 What are the requirements for obtaining a prescriptive easement? Continuous and uninterrupted use for the statutory time: the claimant Laws in the United States differ from one jurisdiction to another. To entitle an easement deed to be recorded in this state, Likewise, since prescriptive easements are not based on written documents recorded in the public records, a prescriptive easement should not be relied upon for legal access and other matters until a court has confirmed that a prescriptive easement does, in fact, exist. Cullen, 26 Wn. Eoff, 271 Or 7, 530 P2d 49 (1975). 1 Answer The requirements for establishing a prescriptive easement are similar to those for adverse possession. See Brown v. RCW 7. An easement is a nonpossessory right to use and/or enter onto the real property of another . The Court’s conclusion gives the public an unfet-tered right to access the maintenance area of a public prescriptive easement. Mutual. through explicit expiration, such as a right of way granted for a period of 25 years. The legal term for this is "adverse possession. More than 15 years ago, we bought a tiny rental property on a rolling knoll overlooking Puget Sound via a tax-deferred exchange. This was the result in a Washington state case when neighbors treated a driveway as their own for 40 years, finally expanding it into a road. A prescriptive easement is an easement upon another's real property acquired by continued use without permission of the owner for a legally defined period. Contract legal services for the States of Idaho, Montana, and Washington. Oct 10, 2013 Prescriptive easements and the doctrine of lost modern grant A claim for a prescriptive easement will be defeated if at any time during the  An easement grants rights for your property to others who don't own the land. at this time County, Washington who own land adjacent to the former railroad easement acquired by the King County in 1998. 69174-1-1 behalfof her marital community, Appellant, V. Luckey v. As I have just had to learn the time frame here in washington, I can inform you that prescriptive easements require 10 years to be valid. Judge granted a preliminary injunction to people who have an easement they have deeded to them but no one has ever opened. In Washington the period of time for adverse possession must be at least seven (7) years. 1 Washington St. ” In fact, Kunkel sstates that regardless if for adverse possession or prescriptive easement: A non-exclusive easement may vary in duration. The courts have long held that “time does not run against the King. Posted What Is Prescriptive Easement, Exactly? 0 Comments Add a Comment. A prescriptive easement is simply a right to use property, the user does not gain title to the easements was created by the courts in England and the United States over . The. U. Th State-by-State Rules on Adverse Possession In some circumstances, a trespasser who comes onto your land and occupies it may gain legal ownership of it. In the world of real estate law, adverse possession and prescriptive has openly used another person's property for an extended period of time. Terms: Expiration: The termination of an easement based on the elapsing of the time for which the easement was originally scheduled to last. Q. 79. Because the County Court based its decision against Mr. A driveway ran from the cabin. Jul 17, 2008 OF JUSTICE, Washington, D. What that means is that the person who has the right to use the Easement is not the owner of the property; the person merely has a limited right to use the property. Cases involving claims to title and use run the gamut in terms of how they are resolved. Nice v. Prescriptive easements are created through a pattern of use and are granted after the person using the easement has used the property in a hostile, continuous and open manner for a costs for establishing the prescriptive easement. However, an easement can also be granted by adverse possession, which is known as a prescriptive easement. The answer depends on whether the 35 ft easement you mention is an expressly granted easement. Non-exclusive easements are generally perpetual in nature and “attach” to the land. An easement may be acquired by prescription if one engages in visible ("open and notorious") use of another's property in a continuous manner for the period of the statute of limitations. State of California Tenants in Common Law. Unlike easement of necessity, the benefit to the dominant tenement must be reasonably necessary to the use and enjoyment of the property, not strictly necessary. The facts are fairly straightforward: an individual owned property burdened by an easement for ingress/egress, which benefited his neighbors. One of the most common ways in which several neighbors may gain prescriptive easement to a particular road or driveway is by using said road or driveway for several years without being challenged by the owner. For prescriptive easements to become legally valid private property easements, the unauthorized, observable use of the property must continue for a specific period of time. In January 2011, Mr. Such acts must continue uninterrupted for the time period defined by state laws, which vary by state. C. Kunkel starts out: “In a claim for a prescriptive easement, the use of another’s property is presumed to be permissive. Easement Agreements Legal in Washington. easement for the first time in 2002, we assume the government first locked the gate and denied access in November . " Hancock cited the Gamboa case in Washington State Supreme Court that involved an Answer to Easements. Moreover, the Court held non-historical use of the easement could inform a determination of the easement’s width. However, hooking up to an existing sewer easement Trespass, Adverse Possession and Prescriptive Easements . Prescriptive easements, also known as easements by prescription, arise if an individual has used an easement in a certain way for a certain number of years. 0. I''m also concerned that a fire truck, the aid car, easement, thereby arguably possessing it, without the right losing its character as an easement. • An easement is the right to use the physical thing that is Then state law provides an “open-lands exception” to prescriptive easements. Private easement over state lands. To establish a prescriptive easement, the person claiming the easement must use another person's land for a period of 10 years and show that (1) he or she Justice Smiles’ managing attorney Robert WM Zierman has read and spreadsheeted virtually all of Washington States’ recorded Adverse Possession cases. Prescriptive easements may be difficult for an owner to  Acquiring an easement by prescription today is similar to acquiring title to land by All states have statutes specifying a time period within which a person must  Mar 13, 2012 When a claim of adverse possession is made two things may happen at not to, we also can find ourselves caught up in the emotion of it all at times. 090. Hancock wrote, "The defendants now have the audacity to assert that they have a prescriptive easement as a matter of law. 320. The user gets an easement by openly, adversely, continuously, and exclusively using the land for a number of years specified by state statute A prescriptive easement is lost by at least five years of nonuse. Merger of Title: The termination of an easement that occurs when the person or entity who holds the easement acquires title to the servient tenement or when the same person attains ownership • Prescriptive easement: This arises when someone uses part of your property without your permission over a period of time. The elements for finding an easement by implication or an implied easement are: There has been unity of title – both lots were at one time owned by the same person; Recently, an interesting issue developed over the applicability of Washington State’s statute regarding waste caused to an easement. In such a case, the easement would have to have a time limit that was set at the time that the easement was created. Licenses –A license is a privilege personal to the holder. Implied easement. To establish a prescriptive easement, a claimant must prove use of the servient land that is: (1) open and notorious, (2) over a uniform route, (3) continuous and uninterrupted for 10 years, (4) adverse to the owner of the servient land; and (5) with the knowledge of the owner of the servient land, at a time when he is able in law to assert and enforce his rights. Implied Easements – You cannot deny how the property has been used in the past. Th Washington Easement Deed. Easements v. 2 (footnotes omitted). using someone else's property openly and continuously for a set period of time . Prescriptive Easements: A Comprehensive Guide Everyone enjoys a surprise now and then. Such use must be open and notorious and must continue, uninterrupted, for a period of 10 years. Shorett v . IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON interest in the driveway under theories of adverse possession and prescriptive easement. • A “road” is not an easement, and an “easement” is not a road. | Washington State A solar easement can only be created by written agreement, but is not authorized to be created by an implied or prescriptive easement (RCW 64. The neighboring landowner is hostile and has arranged two trailers right at the edge of the 10 feet. , for Appellant. Two neighbors live along this private road and use it to access their driveways. use of other's property by common consent was inevitable in a time of no public roads. Adverse possession is a means by which someone may acquire title to the land of another through certain acts over a defined period of time. by: Arthur B. A person may acquire an easement by using the servient land a particular way for a long period of time. To obtain a prescriptive easement, a plaintiff must show use of the land as though it were an easement for ten years in an open and notorious manner that is continuous and adverse to the rights of the servient owner. They take at least 10 years of continuous use by the dominant estate as if the owner of the dominant estate held an express easement for that use. While a letter or filing of a Complaint may be in and of itself sufficient to bring a neighbor to the table to reach reasonable resolution, other matters may lead to full litigation of the dispute. Licenses are permissive, and normally specify the beneficiary, the allowed use, and a time period. Rev. In general, possession of property owned by another is presumed to be non-permissive. The common law of Massachusetts states that the use of the property must have been open, notorious, adverse, and exclusive for those 20 years. Nothing could be further from the truth, as the plaintiffs have ably shown in their opposition to the defendants' motion for reconsideration. Consequently, to start the prescriptive period, the adverse use of the easement must be clearly hostile to the dominant estate's interest in order to put the dominant estate owner on notice. Prescriptive easements are fairly complicated, but to simplify them, they're created over time. Synopsis: This article discusses Idaho law defining prescriptive or adverse possession the fifth element—the statutory period to establish a prescriptive easement—was . Seattle real estate attorneys, such as those at Dickson Frohlich, PS, are trained to understand the idiosyncrasies of real estate law. Hart, August 2007 Scope: The following is an outline of the common ways that easements are created in Washington other than by express grant, but rather through various judicial doctrines, and in some cases, by private condemnation. In the case of adverse possession the intention is to obtain full ownership. Washington Fed'n of State Employees v. " Nw. Example: One of the most common ways in which several neighbors gain a prescriptive easement is by using a driveway or road on another's land for many years without being challenged by the owner. The Law of Easements and Licenses in Land, § 5. prescriptive easement time washington state

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