Willard v. First Church of Christ, Scientist

In Willard v. First Church of Christ, Scientist (1972) 7 Cal.3d 473, the Supreme Court held that in deeding property to one person, the grantor may reserve an interest in the property for another person and rejected the common law rule that "one cannot 'reserve' an interest in property to a stranger to the title." ( Id. at p. 476.) Willard involved a reservation of parking rights for a church. The parking rights were reserved due to the creation of an easement which was expressly stated in the original (but not subsequent) deed as follows: "the conveyance was 'subject to an easement for automobile parking during church hours for the benefit of the church . . . such easement to run with the land only so long as the property whose benefit the easement is given is used for church purposes.'" ( Id. at p. 475.)