Seventh Circuit: Pipeline Easement Challenges Require Breach of Express Terms, Not Mere Reasonableness Arguments

The Seventh Circuit affirmed summary judgment for Trunkline Gas Company, holding that a landowner challenging pipeline maintenance activities bears the burden of demonstrating breach of the easement's express terms, not merely that proposed repairs are unreasonable or unnecessary. Close Armstrong failed to create a genuine dispute of material fact regarding whether Trunkline's pipeline maintenance fell within the scope of the easement agreement's operation and maintenance provisions.