In Exxon Corp. v. Schutzmaier, 537 S.W.2d 282 (Tex. Civ. App.--Beaumont 1976, no writ), the court found an easement by estoppel was created where the only means of ingress and egress was by the road at issue and the access was used for twenty-two years without interference from the defendant.
Additionally, the landlocked owners had expended money on their property to make improvements in reliance upon an express easement obtained by their predecessors.
The Exxon court also noted that the doctrine of easement by estoppel has not been applied with the same strictness as easements by implication. Id. at 285.