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Case No. 23-1845

Mark Fink and Stacy Fink
v.
Donald Lawson and Linda Lawson

In quiet title action involving an easement dispute, defendants appealed district court orders denying their claims of an easement over plaintiffs’ property. The court of appeals affirmed in part, reversed in part, and remanded for further proceedings. Both parties seek further review.

County:
Delaware
Trial Court Case No.:
EQCV008882

Resister

Mark Fink and Stacy Fink

Applicant

Donald Lawson and Linda Lawson

Attorneys for the Resister

Abram V. Carls
Joseph J. Porter

Attorney for the Applicant

Matthew J. Haindfield

Supreme Court

Oral Argument Schedule

15-15-5

Nov 12, 2025 9:00 AM

Briefs

Supreme Court Opinion

Opinion Number:
23-1845
Date Published:
Jan 09, 2026

Court of Appeals

Court of Appeals Opinion

Opinion Number:
23-1845
Date Published:
Feb 05, 2025
Summary

            Appeal from the Iowa District Court for Delaware County, Margaret L. Lingreen, Judge.  AFFIRMED IN PART, REVERSED IN PART, AND REMANDED FOR FURTHER PROCEEDINGS.  Heard by Ahlers, P.J., and Badding and Buller, JJ.  Opinion by Ahlers, P.J.  (15 pages)

            Donald and Linda Lawson appeal from a judgment decree quieting title of two parcels of land in their neighbors after their neighbors brought an action to quiet title and raise several tort claims against the Lawsons.  The Lawsons argue they have an easement running through the parcels.  They also argue that the district court abused its discretion by bifurcating the quiet-title issue and tort claims and addressing the quiet-title issue first.  OPINION HOLDS: The Lawsons do not have a valid express easement, easement by implication, modified prescriptive easement, or easement by acquiescence.  The district court did not abuse its discretion when it bifurcated the quiet-title issue from the tort claims and addressed the quiet-title issue first.  However, because there is a factual dispute as to whether the Lawsons have a valid prescriptive easement, the district court erred by granting summary judgment on that claim.  We reverse the district court’s summary judgment ruling on that issue.  We remand for further proceedings.

Other Information

Date Further Review is Granted:
Apr 10, 2025
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