Given that state law looks to intent of parties, deeds conveying a strip of land for purposes of a right of way conveyed a right of way -- the habendum clause merely held the easement to exist in fee simple, some deeds stated a reversionary interest for the easement, and the state took the burden of providing sufficient drainage for the use.
Since 2011. An occasional commonplacing of the U.S. Circuit Courts of Appeal.
Neither an authoritative statement of the law nor legal advice. Quick work.