Sunnyside Valley Irrigation District v. Dyke Dickie

Summary

The Washington Supreme Court held that a floating easement may be widened over time when its express terms manifest a clear intention by the original parties to modify the initial scope based on future demands, and concluded that the 1908, 1912, and 1925 easements' 'enlargement and repair' and 'maintain and repair the same' language gave SVID that right. Applying the doctrine of reasonable enjoyment, the Court affirmed the trial court's substantial-evidence-supported determinations that the parties anticipated increased flow from the Roza Division, that SVID may use power equipment, and that 20 feet from the lateral's center line is reasonably necessary for maintenance. The Court accordingly affirmed the Court of Appeals and declined to reach Dickie's separate permanent-injunction and state constitutional-taking arguments because SVID operated within the easements' legal authority.