In 1910 K occupied an "old" house located on the westerly portion of her lot fronting on H Street. She built a "new" house on the east side of the lot, moved into it, and rented the "old" house to tenants. As a means of access to the west side and rear of the "new" house, she built and used a sidewalk which led from H Street between the two houses and which was one foot from the west side of the "new" house. This walk "was the only outdoor means of access to the new house's coal chute."
Ralph W. Aigler,
Real Property - Easements by Implication - Creation of Easements By Implied Reservations in Michigan,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol59/iss3/5