Mee Wah Chan v. Y & Development Corp.
Cases that cite this one
5 later published cases cite this decision.
- Isnady v. Walden Preserv., L.P. (Appellate Division of the Supreme Court of New York 2022)
- DiDonato v. Dyckman (Appellate Division of the Supreme Court of New York 2018)
- Courtney v. 18th & 8th LLC (Appellate Division of the Supreme Court of New York 2016)
- Old Town Tree Farm, Inc. v. Long Island Power Authority (Appellate Division of the Supreme Court of New York 2012)
- Old Town Tree Farm, Inc. v. Long Island Power Authority (Appellate Division of the Supreme Court of New York 2012)
This list shows which later cases cite this one. It does not say how they treated it, and no review of that has been done. Not a substitute for Shepard’s or KeyCite — verify before relying.
Opinion of the Court
The defendants failed to make a prima facie showing of entitlement to judgment as a matter of law by conclusively negating any one of the elements of an easement by prescription which, if proven by the plaintiffs at trial, would warrant the recognition an easement by prescription (see Gravelle v Dunster, 2 AD3d 964 [2003]). Contrary to the Supreme Court’s determination, the plaintiffs’ failure to allege or establish that they either “usually cultivated or improved” the disputed property or “protected [it] by a substantial inclosure” is not a basis upon which to award summary judgment to the defendants, since those are requirements relevant only to a claim of adverse possession, and not to the existence of an easement by prescription (RPAPL 522 [former (1), (2)]; cf. RPAPL 522 [1], [2], as amended by L 2008, ch 269; see Di Leo v Pecksto Holding Corp., 304 NY 505, 511 [1952]; City of Tonawanda v Ellicott Cr. Homeowners Assn., 86 AD2d 118, 123 [1982]). Accordingly, the Supreme Court should have denied the defendants’ motion for summary judgment, in effect, declaring that the plaintiffs do not have an easement by prescription over the subject real property.
However, we do not agree with the plaintiffs’ argument that
Case-law data current through December 31, 2025. Source: CourtListener bulk data.