The land originally conveyed in a state land grant was eventually severed into two parcels in 1866. Today, one of those parcels (the Staley tract) is landlocked in the sense that it has no connections to nearby roads and so cannot be accessed without the permission of other neighboring owners. The current owners sued, arguing that the doctrine of easement by necessity should compel finding an easement across the other half of the original land grant (the Stiles tract) to connect to a state road running through the area. The trial court ruled against them.

The court of appeals affirmed, holding that this record did not support an easement by necessity. The Texas Supreme Court agreed, affirming the judgment below.

The key to the Court's decision is timing. As the Court explained:

Maps introduced into evidence showed roads in the vicinity of CR 134 may have existed as early as the 1930s, but there was no evidence of a public roadway through the Stiles Tract or along its northern boundary before that time.

The Court explained that a landowner claiming an easement by necessity must show the presence of a public roadway at the time of the original severance of the two parcels. Here, that severance was in 1866. And there was no evidence that—in 1866—any easement could have been drawn to connect to a public road.