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Ap & Dp, LLC v. Andy Dendinger

2026-08-21

Summary

Holding. The Court of Appeals affirmed the circuit court's grant of summary judgment for the appellees, holding that an easement by necessity cannot be established without unity of ownership of the dominant and servient estates, which the appellant property lacked, and therefore the claim must fail as a matter of law.

AP & DP, LLC purchased a 32.08-acre landlocked parcel of land at auction in Spencer County, Kentucky, knowing at the time of purchase that it had no public or private road access and was surrounded by properties owned by the Dendingers, R&B Farms, and the Army Corps of Engineers. Seven years later, the buyer sued seeking a court declaration granting an easement by necessity across the neighboring properties to access its land.

The circuit court granted summary judgment dismissing the claim, finding that the buyer failed to satisfy the legal requirements for establishing an easement by necessity. On appeal, the Kentucky Court of Appeals affirmed, holding that Kentucky law requires three elements for such an easement: unity of ownership between the two properties at some point, a severance of that unity through conveyance, and necessity of access. The court found that because the buyer's property never shared common ownership with the neighboring parcels, this foundational requirement could not be met, regardless of public policy favoring land use.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether an easement by necessity can be granted without prior unity of ownership between properties
  • Whether public policy favoring beneficial use of land can override established easement prerequisites
  • Whether a property owner's knowledge of landlocked status at purchase affects easement rights

Procedural posture

The appellant appealed a summary judgment order from Spencer Circuit Court granting motions to dismiss filed by the appellees, which were converted to motions for summary judgment when matters outside the pleadings were considered.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion

majority opinion

RENDERED: AUGUST 21, 2026; 10:00 A.M.

TO BE PUBLISHED

Commonwealth of Kentucky

Court of Appeals

NO. 2025-CA-0295-MR

AP & DP, LLC APPELLANT

APPEAL FROM SPENCER CIRCUIT COURT

v. HONORABLE MELANIE BRUMMER, JUDGE

ACTION NO. 24-CI-00045

ANDY DENDINGER; KASEY

DENDINGER; AND R&B FARMS,

LLC APPELLEES

OPINION

AFFIRMING

** ** ** ** **

BEFORE: CALDWELL, L. JONES, AND TAYLOR, JUDGES.

JONES, L., JUDGE: AP & DP, LLC1 (Appellant) brings this appeal from a

February 20, 2025 Opinion and Order of the Spencer Circuit Court granting

1

AP & DP, LLC is a registered limited liability company organized under the laws of the Commonwealth of Kentucky. The members of AP & DP, LLC are Douglas W. Peters and Andrew W. Peters.

summary judgment in favor of Andy Dendinger and Kasey Dendinger

(Dendingers) and R&B Farms, LLC (R&B Farms). We affirm.

On July 27, 2017, Appellant purchased a 32.08-acre tract of land

located on Taylorsville Lake in Spencer County, Kentucky. Appellant purchased

the property at auction which had been advertised as: “Frontage along Corp of

Engineer base flood elevation for Taylorsville Lake!” and “Sold ‘As-Is Where-Is’

to highest bidder!” Trial Record (R.) at 42. Also included in the advertisement for

auction was a map prepared by the Property Valuation Administrator that clearly

depicted the 32.08-acre tract as landlocked. There are no public roads, private

roads, or waterways connected to the property. The 32.08-acre tract is bound on

all sides by the following three properties: (1) property owned by R&B Farms

located at 574 Cull Road; (2) property owned by the Dendingers located at 573

Cull Road; and (3) property owned by the United States of America Army Corps

of Engineers (Army Corps). The Army Corps property is located directly on the

lake and lies between the 32.08-acre tract and the lake, thus preventing direct

access to the tract from the water.

A few months after Appellant purchased the property, Douglas W.

Peters (Douglas) wrote a letter to the Dendingers. In the letter, Douglas

acknowledged knowing the property was landlocked when the purchase was made.

Douglas proposed purchasing an easement across the Dendingers’ property for

-2-ingress and egress to the 32.08-acre tract, or, in the alternative, selling the entire

32.08-acre tract to the Dendingers. R. at 126. The Dendingers responded they

were not interested in either option presented by Douglas.

Some seven years after purchasing the 32.08-acre tract, Appellant

filed a Complaint in the Spencer Circuit Court against, inter alios, R&B Farms and

the Dendingers (collectively referred to as Appellees). In the Complaint filed on

March 8, 2024, Appellant sought a declaration of rights granting it an easement by

necessity through the adjacent properties owned by Appellees located at 574 and

573 Cull Road. R&B Farms filed a Motion to Dismiss pursuant to CR2 12.02 and

asserted Appellant had failed to state a claim upon which relief may be granted.

More particularly, R&B Farms noted Appellant’s only claim was for an easement

by necessity which fails as a matter of law as there is no unity of ownership

between the dominant and servient estates. The Dendingers subsequently filed a

Motion to Dismiss and incorporated by reference the Motion to Dismiss filed by

R&B Farms.

Appellant responded to the Motions to Dismiss and also filed a CrossMotion for Summary Judgment. Therein, Appellant acknowledged there was no

unity of title between Appellant’s property and Appellees’ properties, and the

properties had not been severed from the same tract. Nevertheless, Appellant

2

Kentucky Rules of Civil Procedure.

-3-sought a declaration of rights for an easement by necessity based upon public

policy favoring the beneficial use of land.

By Opinion and Order entered February 20, 2025, the circuit court

denied Appellant’s Motion for Summary Judgment and granted Appellees’

Motions to Dismiss which were converted to Motions for Summary Judgment as

matters outside the pleadings were considered. CR 12.03; see Harrodsburg Indus.

Warehousing, Inc. v. MIGS, LLC, 182 S.W.3d 529, 533 (Ky. App. 2005) (holding

that “[w]here matters outside the pleadings are considered on a motion to dismiss

for failure to state a claim, the motion must be treated as one for summary

judgment”).

The February 20, 2025 Opinion and Order granting summary

judgment in favor of Appellees provided:

The three prongs of an easement by necessity are

defined in Carroll v. Meredith, 59 S.W.3d 484 (Ky. []

App. 2001). Under the current Kentucky case law, a

claim for an easement of necessity fails when it cannot

establish unity of ownership of the dominant and servient

estates.

In the instant case, [Appellant] concedes that there

is no unity of ownership between the dominant and

servient estates, as the servient estate is presently

underwater. The Army Corps[] of Engineers in

establishing Taylorsville Lake in Spencer County,

Kentucky, took possession of real estate in the area used

to construct the lake and real estate surrounding the lake

project, through eminent domain. . . . [Appellant] asserts

that accessing their real property via Taylorsville Lake

-4-and then USA/Army Corps[] property/real estate, is

trespassing, and they do not have the legal right to

traverse this property. The property is landlocked, and

[Appellant’s] members knew this at the time of purchase.

In the final analysis, [Appellant] now seeks access

to their landlocked property by establishing an easement

by necessity through the land of another. They have

accessed the property to date by the nearby lakeshore and

then transversing USA/Army Corps[] of Engineer

property without incident (no evidence in the record to

the contrary). Although Kentucky public policy favors

[Appellant] to be able to access and utilize this real

estate, the Court is unwilling to deviate from the doctrine

of stare decisis under these circumstances, due to

Kentucky public policy concerns.

R. at 195-96. This appeal follows.

Summary judgment is governed by CR 56.03 which provides

summary judgment is appropriate where there exists no genuine issue of material

fact and the moving party is therefore entitled to judgment as a matter of law. In

other words, summary judgment may be granted when “as a matter of law, it

appears that it would be impossible for the respondent to produce evidence at the

trial warranting a judgment in his favor and against the movant.” Steelvest, Inc. v.

Scansteel Serv. Ctr., Inc., 807 S.W.2d 476, 483 (Ky. 1991) (internal quotation

marks and citation omitted). A “circuit court’s decision to grant summary

judgment is reviewed de novo.” Carroll v. Carroll, 355 S.W.3d 463, 466 (Ky.

App. 2011). And, a party opposing summary judgment must present affirmative

evidence to defeat a properly supported motion for summary judgment. Id. at 469.

-5-Appellant contends the circuit court erred by granting summary

judgment in favor of Appellees thereby denying Appellant an easement by

necessity across Appellees’ property. Essentially, Appellant acknowledges it

cannot meet the requirements of an easement by necessity but urges this Court, as a

matter of public policy, to grant such an easement.

It is well settled that “[a]n easement by necessity is based primarily on

the policy favoring beneficial use of property.” Gosney v. Glenn, 163 S.W.3d 894,

900 (Ky. App. 2005) (citations omitted). There are, however, three prerequisites to

the creation of an easement by necessity: “(1) unity of ownership of the dominant

and servient estates; (2) severance of the unity of title by a conveyance of one of

the tracts; and (3) necessity of the use of the servient estate at the time of the

division and ownership to provide access to the dominant estate.” Id. (citations

omitted). As to the third prerequisite, the necessity of access “has generally been

defined as absolute necessity such as where property is landlocked or otherwise

inaccessible.” Meredith, 59 S.W.3d at 491 (citations omitted). Furthermore,

“[e]asements are not favored, and the party claiming the right to an easement bears

the burden of establishing all the requirements for recognizing the

easement.” Gosney, 163 S.W.3d at 899 (citations omitted).

In the case sub judice, it is undisputed that Appellant’s property is

landlocked. It is further undisputed that the property has neither unity of title nor

-6-ownership with the properties owned by Appellees. More particularly, Appellant

concedes the 32.08-acre tract was “severed from an entirely separate tract” and that

“the tract to which [Appellant’s] property belonged and was severed from is now

completely underwater. Thus, there is no servient estate from which [Appellant]

can seek an easement by necessity, it is an impossibility.” Appellant’s Brief at 7.

Appellant concedes the prerequisites to establishing an easement by necessity

cannot be satisfied. Nevertheless, Appellant asserts that if Kentucky precedent

were followed Appellant would have no remedy and the landlocked property

would be rendered useless. Therefore, Appellant believes an easement by

necessity based upon public policy favoring beneficial use of land should prevail

regardless of precedent.

While we agree public policy favors the beneficial use of land, the law

of this Commonwealth is clear that a prerequisite to the creation of an easement by

necessity is unity of ownership of the dominant and servient estates. See Gosney,

163 S.W.3d at 900. Here, it is undisputed there was no unity of ownership. In

fact, not only does Appellant acknowledge there is no unity of ownership between

the tracts, Appellant admittedly possessed knowledge of the landlocked status of

the property at the time of purchase. Although we are cognizant of the precarious

situation Appellant finds itself in, we are constrained to follow the well-established

precedent of this Commonwealth regarding the prerequisites for establishing an

-7-easement by necessity. As there is no unity of ownership, the circuit court

properly denied Appellant an easement by necessity across Appellees’ properties.

We view any remaining contentions of error as moot or without merit.

For the foregoing reasons, we affirm the February 20, 2025 Opinion

and Order of the Spencer Circuit Court granting summary judgment in favor of

Appellees.

ALL CONCUR.

BRIEFS FOR APPELLANT: BRIEF FOR APPELLEES:

Molly Robertson Arneson Corey M. Thomas

Jessica D. Smith Cheryl R. Winn

Louisville, Kentucky Louisville, Kentucky

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