The Iowa Court of Appeals ruled on October 7, 2026, in the case of Wesley Jones and Mandy Jones v. Mary Boas (Docket No. 25-1477). The court affirmed a lower court's decision regarding a dispute over an easement on farmland. This ruling affects the property rights of the Joneses and Boas, determining access to an adjoining farm.
The case revolves around three parcels of land: the Jones Property owned by Wesley and Mandy Jones, the Boas Property owned by Mary Boas, and a third parcel previously owned by Richard and Charlotte Goeken. The disagreement centers on the location of an easement that provides access to the Goeken Property. The district court had previously determined that a prescriptive easement existed over Boas’s land, which Boas challenged in her appeal.
The dispute dates back to 1992 when Davis County abandoned part of a county road that ran between the Jones Property and the Boas Property. To address access issues, the owners of the three properties entered into an easement agreement that granted a thirty-foot wide easement for roadway purposes. The agreement required the Joneses and Boas to maintain fences along the easement and not to erect any buildings or obstructions on the land covered by the easement.
Over the years, the properties changed hands, with Boas purchasing her property in 1999 and the Joneses acquiring theirs in 2014. Tensions rose in 2023 when Boas blocked the entrance to the road with farm vehicles, prompting the Joneses to file a lawsuit. They sought claims for breach of contract, slander of title, quiet title, declaratory judgment, and injunctive relief. Boas counterclaimed for trespass and other claims related to the easement.
After a trial, the district court found that Wesley Jones's testimony was credible and supported by a disinterested witness. The court ruled that the Joneses had both an express easement and a prescriptive easement for access over the Boas Property. The court dismissed the remaining claims from both parties. Boas appealed, arguing that the district court improperly found a prescriptive easement and rejected her claims for quiet title and declaratory judgment.
In its ruling, the Iowa Court of Appeals affirmed the district court's decision. Judge Ahlers wrote the opinion, stating, "The district court found that an express easement exists—and the parties are bound by the easement agreement—but the record was unclear whether the land used as a road between the current fences is the land described in the easement agreement." The court noted that even if the land used as a road was not described in the easement agreement, a prescriptive easement existed due to the long-standing use of the road.
The court explained that a prescriptive easement is established when someone uses another's property openly, notoriously, continuously, and hostilely for ten years or more. The court found clear evidence of hostility and a claim of right, as the Joneses had maintained the area and asserted their claim to access the road. The court also noted that the owners of the Boas Property were aware of the open use of the road.
As for Boas's claims for quiet title and declaratory judgment, the court ruled that since the Joneses had established a prescriptive easement, Boas's claims were without merit. The court stated, "This defeats Boas’s quiet title claim, so we find no error in the dismissal of it."
The ruling has significant implications for property rights and easement disputes in Iowa. It reinforces the concept that long-term use of a property can establish a prescriptive easement, even in the absence of clear documentation. This case may serve as a precedent for similar disputes in the future, highlighting the importance of maintaining clear records and understanding property rights.
Looking ahead, it is unclear if Boas will appeal the ruling to a higher court. The court filing did not indicate any related cases pending that could impact this decision.