In H & F Land, Inc. v. Panama City-Bay County Airport & Industrial District, 736 So. 2d 1167 (Fla. 1999), the First District Court of Appeal certified the following question: "Does the Marketable Record Title Act, chapter 712, Florida Statutes, operate to extinguish an otherwise valid claim of a common law way of necessity when such a claim was not asserted within thirty years?" 736 So. 2d at 1169. The Court answered that question in the affirmative. See id. at 1170. The Court then broadly stated that "statutory or common law ways of necessity are subject to the provisions of the Marketable Record Title to Real Property Act." Id. The Court also broadly stated that "MRTA indeed encompasses all claims to an interest in property, including ways of necessity, unless such claims are expressly exempted from MRTA's provisions. " Id. at 1172. In H & F Land, the Court concluded that "based upon the unambiguous language in MRTA referring to 'all claims' and the clear policy underlying MRTA," MRTA encompassed claims to "ways of necessity." 736 So. 2d at 1172. This conclusion was premised on the fact that "a way of necessity is an easement" and that an easement "is more than a mere personal privilege; it is an interest in land." Id. at 1171-72.