PROPERTY LAW
Peter Graham
In Jigliotti Family Trust v. Bloom, 497 P.3d 472 (Alaska 2021), the Supreme Court held that parties to a quiet title action are entitled to a final judgment quieting title separate from a trial court’s findings and conclusions. (Id. at 474). The Jigliotti Family Trust purchased property from an owner that had negotiated use of an access road from the neighboring owner. (Id. at 475). The neighboring owner later sold their property to the Blooms. (Id.). Over at least a decade, the Blooms dictated the terms of the Jigliotti Family Trust’s occasional use of the access road. (Id.). The Trust eventually sought to quiet title to the access road, though the lower court determined that the Blooms had partially extinguished the easement by prescription. (Id. at 480). While it affirmed the decision, the Court held that the parties were nonetheless entitled by Alaska Civil Rule 58 to a separate judgment addressing the legality of the original license and the validity of the easement up to the point on the Bloom’s property where it was now extinguished by prescription. (Id.). The Supreme Court thus held that parties to a quiet title action are entitled to a final judgment quieting title separate from a trial court’s findings and conclusions. (Id. at 474).
