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Canali v. Satre

Court of Appeals of Illinois
688 N.E. 2d (1997)


William and Ida Shultz owned a property that they split into five parcels, Parcels A – E, near Plank Road. At the time the Shultzes owned both Parcels D and E, the only access to Plank Road for both parcels was through Parcel D’s driveway. Then, in 1936, the Shultzes sold Parcel D, and Parcel E became landlocked. In 1941, the Schultzes sold Parcel E. Charles Canali (plaintiff) now owns Parcel E. The Satres (defendants) now own Parcel D. Canali sued the Satres, asserting that he had acquired an implied easement of necessity to the driveway located on Parcel D. The Satres argued that Canali failed to satisfy all the requirements to show an implied easement of necessity because the easement had been dormant for years. The Satres also argued that the statute of limitations barred Canali’s claims. The trial court found for the Satres. Canali appealed.

Rule of Law


Holding and Reasoning (Inglis, J.)

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