Reybold Venture Group IX, LLC v. Summit Plaza Shopping Center, LLC

Summary

The Supreme Court of Delaware reversed the Court of Chancery and held that the property owner created a private express cross-easement by signing and certifying a recorded plan containing a note stating that the cross-easement was established. The County Code's limitation on private enforcement of record-plan notes did not prevent enforcement of the separate private easement, and the easement bound the subsequent purchaser. No separate opinions were issued.