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The owner of a dominant parcel has not used a recorded road easement for 12 years because a public road became available. No written release was signed.
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Nonuse alone usually does not terminate an easement, but nonuse plus affirmative acts clearly showing intent to abandon may do so. An easement cannot ever terminate after it is recorded. An easement terminates whenever the servient owner dislikes the dominant owner's planned use. Mere nonuse for several years automatically terminates an express easement.

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