My inlaws had a section of BLM that was landlocked inside a ranch that they owned. My FIL had it surveyed and fenced so that there wasn't any question about what was deeded and what was BLM. The last guy from BLM who I spoke to about that lease told me that the only people with an implied easement across the deed land to the BLM land would be the grazing lease holder and the BLM peronnel. My inlaws held the grazing lease on that section of BLM, as did the previous owner, and I believe that the current owner has the grazing lease now.
