In Moran v. Sims, where the house Sims built was surrounded by land owned by Moran, and Sims sued for an easement for access to his house, the courts held that:

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The courts held that Sims did not have an easement, but Moran could not block Sims from driving to get to his property, so he had an equitable right to access his property. This is known as a right of way and is different from an easement.

In Moran V