adverse possession claim (North Dakota) · Go Syfert
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adverse possession claim in North Dakota

10 North Dakota opinions name it 1 courts 1999–2025 2 in the last five years

The cases below were cited by North Dakota 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 (9)

CaseFollowedCited
Production Credit Ass'n of Mandan v. Terra Vallee, Inc.green
nd · 1981 · cited in 2 North Dakota opinions naming this issue, 2001–2002
2 sentences

2002Because acquiescence evolved from and is a supplement to the doctrine of adverse possession, see Production Credit Ass’n v. Terra Vallee, Inc., 303 N.W.2d 79, 83-84 (N.D.1981), we conclude the part of the railroad right of way at issue in this case is not subject to the doctrine of acquiescence.

2001Production Credit Association v. Terra Vallee, Inc., 303 N.W.2d 79, 83-84 (N.D.1981).

22
Sickler v. Popegreen
nd · 1982 · cited in 2 North Dakota opinions naming this issue, 1999–1999
2 sentences

1999See Sickler v. Pope, 326 N.W.2d 86, 91 (N.D.1982); see also Tavis v. Higgins, 157 N.W.2d 718, 719 (N.D.1968).

1999See Sickler v. Pope , 326 N.W.2d 86, 91 (N.D. 1982); see also Tavis v. Higgins , 157 N.W.2d 718, 719 (N.D. 1968).

22
Tavis v. Higginsgreen
nd · 1968 · cited in 2 North Dakota opinions naming this issue, 1999–1999
2 sentences

1999See Sickler v. Pope, 326 N.W.2d 86, 91 (N.D.1982); see also Tavis v. Higgins, 157 N.W.2d 718, 719 (N.D.1968).

1999See Sickler v. Pope , 326 N.W.2d 86, 91 (N.D. 1982); see also Tavis v. Higgins , 157 N.W.2d 718, 719 (N.D. 1968).

22
Torgerson v. Rosegreen
nd · 1983 · cited in 1 North Dakota opinions naming this issue, 2015–2015
1 sentence

2015See Benson v. Taralseth, 382 N.W.2d 649, 652-53 (N.D.1986) (applying the elements of adverse possession for a claim under N.D.C.C. 47-06-03); Torgerson , at 83-84 (applying elements of adverse possession for claim under N.D.C.C. 28-01-08); Simons v. Tancre, 321 N.W.2d 495, 498-99 (N.D.1982) (holding a claimant must establish all of the elements of an adverse possession claim even if the statutory requirements of N.D.C.C. 28-01-08 are met); Martin v. Rippel, 152 N.W.2d 332, 338 (N.D.1967) (applying elements of adverse possession for claim under N.D.C.C. 28-01-10). [¶ 16] In proving all the elem

11
Benson v. Taralsethgreen
nd · 1986 · cited in 1 North Dakota opinions naming this issue, 2015–2015
1 sentence

2015See Benson v. Taralseth, 382 N.W.2d 649, 652-53 (N.D.1986) (applying the elements of adverse possession for a claim under N.D.C.C. 47-06-03); Torgerson , at 83-84 (applying elements of adverse possession for claim under N.D.C.C. 28-01-08); Simons v. Tancre, 321 N.W.2d 495, 498-99 (N.D.1982) (holding a claimant must establish all of the elements of an adverse possession claim even if the statutory requirements of N.D.C.C. 28-01-08 are met); Martin v. Rippel, 152 N.W.2d 332, 338 (N.D.1967) (applying elements of adverse possession for claim under N.D.C.C. 28-01-10). [¶ 16] In proving all the elem

11
Simons v. Tancregreen
nd · 1982 · cited in 1 North Dakota opinions naming this issue, 2015–2015
1 sentence

2015See Benson v. Taralseth, 382 N.W.2d 649, 652-53 (N.D.1986) (applying the elements of adverse possession for a claim under N.D.C.C. 47-06-03); Torgerson , at 83-84 (applying elements of adverse possession for claim under N.D.C.C. 28-01-08); Simons v. Tancre, 321 N.W.2d 495, 498-99 (N.D.1982) (holding a claimant must establish all of the elements of an adverse possession claim even if the statutory requirements of N.D.C.C. 28-01-08 are met); Martin v. Rippel, 152 N.W.2d 332, 338 (N.D.1967) (applying elements of adverse possession for claim under N.D.C.C. 28-01-10). [¶ 16] In proving all the elem

11
Martin v. Rippelgreen
nd · 1967 · cited in 1 North Dakota opinions naming this issue, 2015–2015
1 sentence

2015See Benson v. Taralseth, 382 N.W.2d 649, 652-53 (N.D.1986) (applying the elements of adverse possession for a claim under N.D.C.C. 47-06-03); Torgerson , at 83-84 (applying elements of adverse possession for claim under N.D.C.C. 28-01-08); Simons v. Tancre, 321 N.W.2d 495, 498-99 (N.D.1982) (holding a claimant must establish all of the elements of an adverse possession claim even if the statutory requirements of N.D.C.C. 28-01-08 are met); Martin v. Rippel, 152 N.W.2d 332, 338 (N.D.1967) (applying elements of adverse possession for claim under N.D.C.C. 28-01-10). [¶ 16] In proving all the elem

11
Grandin v. Gardinergreen
nd · 1954 · cited in 1 North Dakota opinions naming this issue, 2015–2015
1 sentence

2015See Grandin v. Gardiner, 63 N.W.2d 128, 133 (N.D.1954).

11
Bernier v. Preckelgreen
nd · 1931 · cited in 1 North Dakota opinions naming this issue, 2008–2008
2 sentences

2008Bernier v. Preckel, 60 N.D. 549, 557 , 236 N.W. 243, 247 (1931).

2008Bernier v. Preckel, 60 N.D. 549, 557 , 236 N.W. 243, 247 (1931).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (5)

CaseCitedYears
Judith M. Woodward v. Thomas J. Valvoda green
wyo · 2021
2 sentences

2025The claimant’s subjective beliefs and intent are not relevant . . . .” (citation omitted)); Woodward v. Valvoda, 2021 WY 5, ¶ 27 , 478 P.3d 1189 (“Because the notice requirement is a fundamental part of an adverse possession claim, a claimant cannot establish a prima facie case by relying solely on his testimony as to his subjective hostile intent.

2025The claimant’s subjective beliefs and intent are not relevant . . . .” (citation omitted)); Woodward v. Valvoda, 2021 WY 5, ¶ 27 , 478 P.3d 1189 (“Because the notice requirement is a fundamental part of an adverse possession claim, a claimant cannot establish a prima facie case by relying solely on his testimony as to his subjective hostile intent.

22025–2025
Winnie Development, LLLP v. Reveling green
nd · 2018
1 sentence

2019The court therefore did not err in holding the platted roadway was subject to an adverse possession claim.1 1 We note that our decision in Winnie Dev., 2018 ND 47, ¶ 9 , 907 N.W.2d 413 , is not dispositive in this case.

12019–2019
Welsh v. Monson green
nd · 1956
1 sentence

2019The court thus found that “as to the platted roadway, there was no action by or on behalf of the public, or by the public authorities, to complete or accept the offer by the owner to dedicate such roadway for public use.” Relying on Welsh, 79 N.W.2d at 158 , the court concluded the platted roadway did not become a public right-of-way held by the township, but instead remained privately owned property and subject to an adverse possession claim. [¶21] Tonneson and Issendorf argue the district court erred in relying on the Welsh case.

12019–2019
Brown v. Brodell green
nd · 2008
1 sentence

2018“Whether there has been mutual recognition of a boundary is a question of fact, and will be reviewed on appeal under a clearly erroneous standard.” Id. [¶11] “Like its sister doctrine of adverse possession, the doctrine of acquiescence allows for the principle of tacking to reach the 20-year requirement.” Id. at ¶ 9.

12018–2018
Thompson v. Associated Potato Growers, Inc. green
nd · 2000
2 sentences

2001Thompson v. Associated Potato Growers, Inc., 2000 ND 95, ¶ 7 , 610 N.W.2d 53 . [¶ 10] The doctrine of acquiescence was created to allow a person to acquire property when occupying part of a neighbor's land due to an honest mistake as to the location of the true boundary, because the adverse intent requirement of the related doctrine of adverse possession *708 could not be met under those circumstances.

2001Thompson v. Associated Potato Growers, Inc., 2000 ND 95, ¶ 7 , 610 N.W.2d 53 . [¶ 10] The doctrine of acquiescence was created to allow a person to acquire property when occupying part of a neighbor's land due to an honest mistake as to the location of the true boundary, because the adverse intent requirement of the related doctrine of adverse possession *708 could not be met under those circumstances.

12001–2001

Statutes the citing opinions construe

ND § N.D. Cent. Code § 28-01-07 (3) ND § N.D. Cent. Code § 28-01-11 (3)

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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