adverse possession doctrine (Illinois) · Go Syfert
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adverse possession doctrine in Illinois

19 Illinois opinions name it 2 courts 1981–2024 3 in the last five years

The cases below were cited by Illinois courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (13)

CaseFollowedCited
Joiner v. Janssengreen
ill · 1981 · cited in 8 Illinois opinions naming this issue, 1989–2024
2 sentences

2024Joiner, 85 Ill. 2d at 80-81 . ¶ 21 As the above precedent demonstrates, title acquired by adverse possession may be used as a basis for an action to quiet title regardless of legal title; the quiet title action is the vehicle through which an adverse possession claim can be made.

1996Our supreme court, when discussing the elements of an adverse possession claim, ruled that " 'improvements or acts of dominion over the land as will indicate to persons residing in the immediate neighborhood who has the exclusive management and control of the land are sufficient to constitute possession.’ ” Joiner, 85 Ill. 2d at 82 , quoting Augustus v. Lydig, 353 Ill. 215, 221-22 (1933).

18
Tapley v. Petersongreen
illappct · 1986 · cited in 2 Illinois opinions naming this issue, 2020–2024
2 sentences

2024See Tapley, 141 Ill.

2020Tapley, 141 Ill.

12
McNeil v. Ketchensgreen
illappct · 2010 · cited in 2 Illinois opinions naming this issue, 2010–2010
2 sentences

2010Joiner v. Janssen, 85 Ill. 2d 74, 81 , 421 N.E.2d 170 (1981); McNeil v. Ketchens, 397 Ill.

2010Joiner v. Janssen, 85 Ill. 2d 74, 81 , 421 N.E.2d 170 (1981); McNeil v. Ketchens, 397 Ill.

12
Malone v. Smithgreen
illappct · 2005 · cited in 2 Illinois opinions naming this issue, 2008–2008
2 sentences

2008Malone v. Smith, 355 Ill.

2008Malone v. Smith, 355 Ill.

12
Kedzie and 103rd Currency Exchange, Inc. v. Hodgegreen
ill · 1993 · cited in 1 Illinois opinions naming this issue, 2024–2024
1 sentence

2024In re Estate of Cargola, 2017 IL App (1st) 151823, ¶¶ 19, 21 (permission to use another person’s land can never ripen into an adverse possession claim). ¶ 16 Section 2-619(a)(9) provides “a means of obtaining *** a summary disposition of issues of law or of easily proved issues of fact, with a reservation of jury trial as to disputed questions of fact.” (Internal quotation marks omitted.) Kedzie & 103rd Currency Exchange, Inc. v. Hodge, 156 Ill. 2d 112, 115 (1993).

11
Kean v. Wal-Mart Stores, Inc.green
ill · 2009 · cited in 1 Illinois opinions naming this issue, 2024–2024
1 sentence

2024A section 2-619(a)(9) motion assumes the allegations in a complaint are true but asserts that the plaintiff’s cause of action is barred by “other affirmative matter avoiding the legal effect of or defeating the claim.” 735 ILCS 5/2-619(a)(9) (West 2022); see also Kean v. Wal-Mart Stores, Inc., 235 Ill. 2d 351, 361 (2009) (section 2-619(a) motion admits the legal sufficiency of the complaint but asserts an affirmative matter outside the complaint that defeats the cause of action).

11
In re Estate of Cargolagreen
illappct · 2017 · cited in 1 Illinois opinions naming this issue, 2024–2024
1 sentence

2024In re Estate of Cargola, 2017 IL App (1st) 151823, ¶¶ 19, 21 (permission to use another person’s land can never ripen into an adverse possession claim). ¶ 16 Section 2-619(a)(9) provides “a means of obtaining *** a summary disposition of issues of law or of easily proved issues of fact, with a reservation of jury trial as to disputed questions of fact.” (Internal quotation marks omitted.) Kedzie & 103rd Currency Exchange, Inc. v. Hodge, 156 Ill. 2d 112, 115 (1993).

11
Mazal v. Ariasgreen
illappct · 2019 · cited in 1 Illinois opinions naming this issue, 2023–2023
1 sentence

2023The reason is that the statutory period of limitation for “commenc[ing] an action for the recovery of lands” or for “mak[ing] an entry thereon” is “20 years after the right to bring such action or make such entry first accrued.” 735 ILCS 5/13-101 (West 2020); see also Mazal v. Arias, 2019 IL App (1st) 190660, ¶ 20 (noting that “[c]auses of action for adverse possession *** are *** incorporated into section 13-101, which sets a 20-year statute of limitation on the recovery of lands”).

11
Brandhorst v. Johnsongreen
illappct · 2014 · cited in 1 Illinois opinions naming this issue, 2022–2022
1 sentence

2022See Brandhorst v. Johnson, 2014 IL App (4th) 130923, ¶ 37 (though not one of the five elements of an adverse-possession claim, the claimant must clearly and convincingly prove “the exact location of the boundary line to which they claim” (emphasis added)).

11
Augustus v. Lydiggreen
ill · 1933 · cited in 1 Illinois opinions naming this issue, 1996–1996
1 sentence

1996Our supreme court, when discussing the elements of an adverse possession claim, ruled that " 'improvements or acts of dominion over the land as will indicate to persons residing in the immediate neighborhood who has the exclusive management and control of the land are sufficient to constitute possession.’ ” Joiner, 85 Ill. 2d at 82 , quoting Augustus v. Lydig, 353 Ill. 215, 221-22 (1933).

11
Marengo Cave Co. v. Rossgreen
ind · 1937 · cited in 1 Illinois opinions naming this issue, 1996–1996
2 sentences

1996While courts in Illinois have not had further occasion to discuss the exclusive requirement of the adverse possession doctrine, other courts have found it to be necessary because "[i]t is evident that two or more persons cannot hold one tract of land adversely to each other at the same time.” Marengo Cave Co. v. Ross, 212 Ind. 624, 633 , 10 N.E.2d 917, 921 (1937).

1996While courts in Illinois have not had further occasion to discuss the exclusive requirement of the adverse possession doctrine, other courts have found it to be necessary because "[i]t is evident that two or more persons cannot hold one tract of land adversely to each other at the same time.” Marengo Cave Co. v. Ross, 212 Ind. 624, 633 , 10 N.E.2d 917, 921 (1937).

11
Nome 2000 v. Fagerstromgreen
alaska · 1990 · cited in 1 Illinois opinions naming this issue, 1996–1996
2 sentences

1996For purposes of the "actual” requirement to adverse possession, the relevant portion of the above statement is that the plaintiffs must prove that they made "improvements or [performed] acts of dominion” (Joiner, 85 Ill. 2d at 82 ) sufficient to "provide the reasonably diligent owner with visible evidence of another’s exercise of dominion and control” (Nome 2000 v. Fagerstrom, 799 P.2d 304, 311 (Alaska 1990)).

1996Nome 2000, 799 P.2d at 311 .

11
In Re Application of County Collectorgreen
illappct · 1981 · cited in 1 Illinois opinions naming this issue, 1989–1989
2 sentences

1989(See Joiner v. Janssen (1981), 85 Ill. 2d 74 , 421 N.E.2d 170 ; see also In re Application of DuPage County Collector (1981), 98 Ill.

1989(See Joiner v. Janssen (1981), 85 Ill.2d 74 , 421 N.E.2d 170 ; see also In re Application of Du Page County Collector (1981), 98 Ill.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Illinois. Read the followed side critically anyway.

Also cited on this issue (5)

CaseCitedYears
Crawford v. Love green
illappct · 1993
2 sentences

2002As early as 1890, Illinois tax deeds have defeated the continuity ‘of the running of [an adverse possessor’s] title, because no 20 years had elapsed from the time he entered until the title accrued under the tax-title.’ ” Crawford, 243 Ill.

2002As early as 1890, Illinois tax deeds have defeated the continuity 'of the running of [an adverse possessor's] title, because no 20 years had elapsed from the time he entered until the title accrued under the tax-title.' " Crawford , 243 Ill.

22002–2002
Leonard v. Leonard green
ill · 1938
2 sentences

1981“Using and controlling property as an owner is the ordinary mode of asserting a claim of title * ° Leonard v. Leonard (1938), 369 Ill. 572, 577 .

1981"Using and controlling property as an owner is the ordinary mode of asserting a claim of title * * *." Leonard v. Leonard (1938), 369 Ill. 572, 577 . • 8 The record before us supports a conclusion that a prima facie case of adverse possession in its essential elements has been shown.

21981–1981
Wijas v. Clorfene green
illappct · 1970
2 sentences

1981While the payment of taxes is a fact to be considered in weighing an adverse possession claim (Wijas v. Clorfene (1970), 126 Ill.

1981App.3d 512, 513-14 . • 7 While the payment of taxes is a fact to be considered in weighing an adverse possession claim ( Wijas v. Clorfene (1970), 126 Ill.

21981–1981
Brown v. Trustees of Schools green
ill · 1906
1 sentence

2019Id. at 189 .

12019–2019
Cagle v. Valter green
ill · 1960
2 sentences

1986(Cagle v. Valter (1960), 20 Ill. 2d 589 , 170 N.E.2d 593 .) Proof, in order to overcome such presumptions, must be clear and unequivocal, and cannot be made by implication or inference.

1986(Cagle v. Valter (1960), 20 Ill. 2d 589 , 170 N.E.2d 593 .) Proof, in order to overcome such presumptions, must be clear and unequivocal, and cannot be made by implication or inference.

11986–1986

Statutes the citing opinions construe

IL § 735 ILCS 5/13-101 (8) IL § 735 ILCS 5/2-619 (6)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

TX 90 (1930–2026) NY 81 (1875–2026) MO 52 (1855–2025) WA 51 (1943–2026) OH 46 (1979–2026) OR 35 (1909–2025) IN 33 (1855–2025) ME 32 (1914–2024) MI 30 (1897–2026) RI 27 (1970–2026) CT 27 (1983–2025) WY 27 (1981–2025) WI 26 (1927–2025) IA 21 (1903–2024) AL 21 (1866–2026) PA 20 (1840–2025) CA 19 (1915–2025) IL 19 (1981–2024) SC 18 (1987–2022) TN 18 (1998–2026) CO 17 (1956–2026) MS 15 (1987–2025) AZ 14 (1979–2024) MN 13 (1988–2026) AR 13 (1959–2021) WV 12 (1892–2025) MD 10 (1984–2018) NH 10 (1984–2025) ND 10 (1999–2025) OK 10 (1924–2014) NC 9 (1919–2025) VT 8 (2013–2025) UT 8 (1989–2025) VA 8 (1938–2026) NM 8 (1969–2003) MA 8 (1979–2025) KY 8 (2009–2025) GA 8 (1999–2023) KS 7 (1974–2024) HI 7 (1905–2016) ID 7 (1892–2024) SD 6 (1997–2026) NJ 6 (1979–2024) DE 5 (1959–2024) NE 4 (2016–2023) FL 4 (1991–2019) AK 3 (1982–2005) NV 3 (1992–2021) VI 3 (2008–2012) DC 2 (2019–2020) MT 2 (1991–2000)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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