In Boucher v. Boyer, 301 Md. 679, 688, 484 A.2d 630 (1984), the Court of Appeals held that application of the "plat reference theory of implied easements" led to the conclusion that the Bouchers had an easement over a street because their deed referred to a plat referencing the street as a right-of-way. The Pipers, owners of an approximate fifteen acre tract in Frederick County recorded a plat establishing two one-acre lots, bisected by a roadway designated as "George Street." Id. at 683-83. The plat indicated that the Pipers were offering to dedicate George Street to public use. Id. at 684. The Pipers conveyed the two lots bounded by George Street to others, in deeds that referenced the Piper Estates plat, and then conveyed the remainder of their interest in the original fifteen acre tract to the Bouchers. Id. at 684. The Court of Appeals held that the "Bouchers had an implied easement over George Street by virtue of the reference in their deed to the Piper Estates plat, which depicts George Street as a right of way to their property." Id. at 695. The Court stated that "a deed that is silent as to the right of way but refers to a plat that establishes such a right of way creates a rebuttable presumption that the parties intended to incorporate the right of way in the transaction." Id. at 689. In Boucher v. Boyer, the appellees challenged the conclusion that Boucher had an implied easement. 301 Md. at 692-93. Appellees argued that former 5-114 of Art. 21 compelled a different result and that former 5-114 of Art. 21 "operates to grant 'all the right, title and interest' of the grantor of the conveyed property in any street bounding upon the property. Because a conveyance of property bounding on a street conveys all right, title, and interest to the center of the street, and because an easement is an 'interest' in the street," in Boucher, appellees contended that the "grantor was statutorily precluded from creating an easement in the street to the grantee." Id. at 693. The Court noted the conflict, stating: "This reasoning would of course effectively abrogate the common law principle that a conveyance of property with reference to a recorded plat creates a rebuttable presumption that rights of way depicted on the plat are intended as easements." Id. The Court resolved the conflict, stating: "To resolve the apparent conflict between these two rules, we must examine the purpose of each and reconcile them if possible. The purpose of former 5-114 is to assure landowners that they will have access to streets bounding on their land by granting to them title to the center line of the street while recognizing an easement in the other half of the street. The implied easement by plat reference rule has an identical purpose, although it accomplishes its objective by creating an easement to the whole of the street rather than by granting fee simple title to part." Id. at 693-94. In Boucher v. Boyer, the Court of Appeals held "that the Bouchers had an implied easement over George Street by virtue of the reference in their deed to the Piper Estates plat, which depicts George Street as a right of way to their property." The Pipers recorded a subdivision plat--the Piper Estates plat--which indicated that they were offering to dedicate George Street, which bounded two lots, to public use. Id. at 683-84. The Pipers conveyed the two lots bounded by George Street in deeds that referenced the Piper Estates plat, and then conveyed the remainder of their interest to the Bouchers. Id. at 684. Frederick County did not accept George Street as a public road, but the Bouchers used George Street to access their property. Id. at 685. Because the Bouchers' deed referenced the Piper Estates plat "as a means of describing the boundaries of their property," the Bouchers had an easement over George Street. Id. at 691. The Court noted that "all grantees from the common grantor (the Pipers) purchased their property with reference to the same plat, and all of the lots either bind or abut George Street. In our view, this indicates that the grantors intended that each grantee have at least an easement over the street." Id. In Boucher, 301 Md. at 691, the Court of Appeals stated: "A conveyance which conveys property by reference to a map or plat, which map or plat shows the property so conveyed is bounded by a road or way, the right-of-way thereover passes by the conveyance as an easement appurtenant thereto." In reviewing whether or not the Bouchers had an implied easement by virtue of plat reference, the Court stated that: As we see it, a deed that is silent as to the right of way but refers to a plat that establishes such a right of way creates a rebuttable presumption that the parties intended to incorporate the right of way in the transaction. See generally Mullan v. Hochman, supra (when a grantor subdivides property shown on a plat as bordering streets he impliedly convenants that the grantee will have an easement over the street shown on the plat). A party may therefore point to the existence of the plat to establish that the parties intended that the right of way depicted in the plat be used by the grantee. In sum, we view this as a reasonable application of the common law rule that a deed reference to a plat incorporates that plat as part of the deed. See Klein v. Dove, supra; Williams Realty Co. v. Robey, 175 Md. 532, 2 A.2d 683 (1938); see also Schickli v. Keeling, 307 Ky. 210, 210 S.W.2d 780 (1948); Goldstein v. Beal, 317 Mass. 750, 59 N.E.2d 712 (1945); Vogel v. Haas, 456 Pa. 585, 322 A.2d 107 (1974). (Boucher, 301 Md. at 689.) In Boucher, in reaching its holding, the Court of Appeals utilized precedent establishing that a plat's depiction of a right of way creates a presumptive easement. Id. at 692. Specifically, the Court of Appeals applied Shadburn, 216 Md. 44, 139 A.2d 339, and Hackerman v. City of Balt., 212 Md. 618, 130 A.2d 732 (1957), discussing the cases as follows: Factually, the Shadburns owned a lot on a Baltimore City block, and appellants owned several lots on the same block. An alley separated the lots on the west side of the block from the lots on the opposite side (east side) of the block. After the appellants obstructed this alley, the Shadburns and others brought suit to enjoin the obstruction. This Court upheld the requested relief, holding that the Shadburns and the other neighbors had a right to use the alley. Because some of the lot owners had express rights of use in their respective deeds, the Shadburn Court held that they had express easements. Although the Shadburns lacked this clause in their deed, we determined that they nonetheless had an easement because the development plat depicted the alley. Id. 216 Md. at 51-52, 216 Md. 44, 139 A.2d 339; see Hackerman v. City of Baltimore, 212 Md. 618, 130 A.2d 732 (1957) (easement by implication may be created when plat depicts a right of way) (dictum). In both Shadburn and Hackerman, we found that a plat that sets out a street or alleyway creates a presumption that a dedication was intended. . . . These cases, together with our discussion of this theory in the context of the instant case, convince us that the Bouchers have an implied easement over George Street. (Boucher, 301 Md. at 692.)