ROBERT D. GIOVANELLI II, and KERITH A. GIOVANELLI Missouri Cases

Jared Ford and Mary Williams, owners of landlocked property, sought to establish a private road by strict necessity over the Giovanellis' property to access their land. The trial court granted their petition, finding strict necessity because their property did not adjoin a public roadway and any use of a U.S. Forest Road required a permit. The Giovanellis appealed, arguing the finding lacked substantial evidence and was against the weight of the evidence, specifically regarding the "Green Road" (Forest Road 1539). The appellate court affirmed, concluding that even if Forest Road 1539 were public and required no permit, it provided neither physical nor reasonably practical access to the Ford-Williams property.