adverse claim (Georgia) · Go Syfert
← Georgia issues

adverse claim in Georgia

73 Georgia opinions name it 2 courts 1897–2025 2 in the last five years

The cases below were cited by Georgia 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 (40)

CaseFollowedCited
First Christian Church v. Realty Investment Co.green
ga · 1934 · cited in 3 Georgia opinions naming this issue, 1965–2001
2 sentences

2001See First Christian Church &c. v. Realty Investment Co., 180 Ga. 35, 39-41 ( 178 SE 303 ) (1934).

2001See First Christian Church &c. v. Realty Investment Co., 180 Ga. 35, 39-41 ( 178 SE 303 ) (1934).

33
Douglas v. Knoxgreen
gactapp · 1998 · cited in 3 Georgia opinions naming this issue, 2001–2023
2 sentences

2023“Repairs performed with the owner’s permission or by agreement cannot establish a prescriptive easement.”6 Thus, the undisputed evidence conclusively establishes that the use of the shared driveway was permissive, not adverse.7 The Lewises argue that they did not need to demonstrate notice of an adverse claim, citing OCGA § 44-9-54, which provides that “[w]henever a private way has been in constant and uninterrupted use for seven or more years and no legal steps 5 (Citations and punctuation omitted.) Douglas v. Knox, 232 Ga. App. 551, 552 (2) ( 502 SE2d 490 ) (1998). 6 Wilkes 581 Farms, LLC v.

2023“Repairs performed with the owner’s permission or by agreement cannot establish a prescriptive easement.”6 Thus, the undisputed evidence conclusively establishes that the use of the shared driveway was permissive, not adverse.7 The Lewises argue that they did not need to demonstrate notice of an adverse claim, citing OCGA § 44-9-54, which provides that “[w]henever a private way has been in constant and uninterrupted use for seven or more years and no legal steps 5 (Citations and punctuation omitted.) Douglas v. Knox, 232 Ga. App. 551, 552 (2) ( 502 SE2d 490 ) (1998). 6 Wilkes 581 Farms, LLC v.

23
Morgan v. Mitchellgreen
ga · 1898 · cited in 3 Georgia opinions naming this issue, 1946–1972
2 sentences

1972Morgan v. Mitchell, 104 Ga. 596, 598 ( 30 SE 792 ).

1946Exclusive possession, therefore, by a cotenant alone will be presumed not an adverse holding, but simply one in support of the common title.” Morgan v. Mitchell, 104 Ga. 596, 598 ( 30 S. E. 792 ).

23
Hobgood v. Blackgreen
gactapp · 1978 · cited in 2 Georgia opinions naming this issue, 2006–2017
2 sentences

2017An “interested” party within the context of the statute is one who “has a protect[a]ble interest and asserts an adverse claim on an accrued statement of facts.” Hobgood v. Black, 144 Ga. App. 448, 449 (2) ( 241 SE2d 60 ) (1978).

2017An “interested” party within the context of the statute is one who “has a protect[a]ble interest and asserts an adverse claim on an accrued statement of facts.” Hobgood v. Black, 144 Ga. App. 448, 449 (2) ( 241 SE2d 60 ) (1978).

22
Walton v. Sikesgreen
ga · 1927 · cited in 2 Georgia opinions naming this issue, 1941–2012
2 sentences

1941He chose to ignore the rights of the latter, and he can not now be heard to say that his building was ‘bona fide placed5 on the property of the plaintiff.” In Walton v. Sikes, 165 Ga. 422, 427 ( 141 S. E. 188 ), *664 the court said: “It has been held by this court that where a defendant enters upon land in good faith under an adverse claim of title, and, after suit is brought against him by one who has actual title to the property, erects improvements upon the land, it can not be held that he has ‘bona fide placed improvements thereon,’ so as to entitle him to set oil the value of such improve

1941He chose to ignore the rights of the latter, and he can not now be heard to say that his building was ‘bona fide placed5 on the property of the plaintiff.” In Walton v. Sikes, 165 Ga. 422, 427 ( 141 S. E. 188 ), *664 the court said: “It has been held by this court that where a defendant enters upon land in good faith under an adverse claim of title, and, after suit is brought against him by one who has actual title to the property, erects improvements upon the land, it can not be held that he has ‘bona fide placed improvements thereon,’ so as to entitle him to set oil the value of such improve

22
Fields v. Yellow Cab. Co. of Atlantagreen
gactapp · 1949 · cited in 2 Georgia opinions naming this issue, 1998–1999
2 sentences

1999Fields v. Yellow Cab Co. & c., 80 Ga.App. 569, 571 , 56 S.E.2d 845 (1949); Speagle v. Nationwide &c.

1999Fields v. Yellow Cab Co. & c., 80 Ga.App. 569, 571 , 56 S.E.2d 845 (1949); Speagle v. Nationwide &c.

22
Denson v. Densongreen
ga · 1958 · cited in 2 Georgia opinions naming this issue, 1974–1998
2 sentences

1998Denson v. Denson, 214 Ga. 8, 9 (1) ( 102 SE2d 605 ) (1958); Hodges v. Hodges, 213 Ga. 689, 694 (2) ( 100 SE2d 888 ) (1957); Wallace v. Mize, 153 Ga. 374, 383 (1) ( 112 SE 724 ) (1922). 5 The statute of limitation begins to run against the party asserting title under an implied trust when there has been notice of an adverse claim by the alleged trustee or such change of circumstances as would put a reasonably prudent person on notice that any trust relationship has ceased.

1998Denson v. Denson, 214 Ga. 8, 9 (1) ( 102 SE2d 605 ) (1958); Hodges v. Hodges, 213 Ga. 689, 694 (2) ( 100 SE2d 888 ) (1957); Wallace v. Mize, 153 Ga. 374, 383 (1) ( 112 SE 724 ) (1922). 5 The statute of limitation begins to run against the party asserting title under an implied trust when there has been notice of an adverse claim by the alleged trustee or such change of circumstances as would put a reasonably prudent person on notice that any trust relationship has ceased.

22
Jay v. Whelchelgreen
ga · 1887 · cited in 4 Georgia opinions naming this issue, 1925–1961
2 sentences

1925If J. executes a security deed to L. as administrator and remains in possession, J's possession is not adverse to the estate represented by L., but is merely permissive (Jay v. Whelchel, 78 Ga. 786 , 3 S. E. 906 ), and will not afford a basis for prescription against L. as administrator or the distributees (if ever before payment of the secured debt) until after an adverse claim by J. and actual notice thereof to L. as administrator.

1925If J. executes a security deed to L. as administrator and remains in possession, J's possession is not adverse to the estate represented by L., but is merely permissive (Jay v. Whelchel, 78 Ga. 786 , 3 S. E. 906 ), and will not afford a basis for prescription against L. as administrator or the distributees (if ever before payment of the secured debt) until after an adverse claim by J. and actual notice thereof to L. as administrator.

14
Hadden v. Thompsongreen
ga · 1947 · cited in 2 Georgia opinions naming this issue, 1949–1949
2 sentences

1949Frost v. Arnaud, 144 Ga. 26 (2) ( 85 S. E. 1028 ); Hadden v. Thompson, 202 Ga. 74, 78 ( 42 S. E. 2d, 125 ).

1949Frost v. Arnaud, 144 Ga. 26 (2) ( 85 S. E. 1028 ); Hadden v. Thompson, 202 Ga. 74, 78 ( 42 S. E. 2d, 125 ).

12
Ewing v. Tannergreen
ga · 1937 · cited in 2 Georgia opinions naming this issue, 1943–1943
2 sentences

1943In Ewing v. Tanner, 184 Ga. 773, 779 ( 193 S. E. 243 ), it was said: “The nature of the possession of personal property and that of realty, required to give title by prescription, is the same.

1943In Ewing v. Tanner, 184 Ga. 773, 779 ( 193 S. E. 243 ), it was said: “The nature of the possession of personal property and that of realty, required to give title by prescription, is the same.

12
Smith v. Csx Transportation, Inc.green
gactapp · 2017 · cited in 1 Georgia opinions naming this issue, 2025–2025
2 sentences

2025Mgmt., 361 Ga. App. 311 , 318 (1) (b) ( 864 SE2d 140 ) (2021) (explaining that “[w]ithout a ruling by the trial court on its claim of spoliation, [appellant] cannot use the unresolved issue of spoliation to assert that genuine issues of material fact nonetheless exist”). 41 See Westmoreland, 362 Ga. App. at 122-23 (holding plaintiff, who was allegedly injured by glass bottles falling through package and onto floor, failed to establish spoliation claim that store’s failure to preserve packaging triggered rebuttable 22 To summarize, Johnson’s allegations that TICO’s mechanics failed to comply wi

2025Mgmt., 361 Ga. App. 311 , 318 (1) (b) ( 864 SE2d 140 ) (2021) (explaining that “[w]ithout a ruling by the trial court on its claim of spoliation, [appellant] cannot use the unresolved issue of spoliation to assert that genuine issues of material fact nonetheless exist”). 41 See Westmoreland, 362 Ga. App. at 122-23 (holding plaintiff, who was allegedly injured by glass bottles falling through package and onto floor, failed to establish spoliation claim that store’s failure to preserve packaging triggered rebuttable 22 To summarize, Johnson’s allegations that TICO’s mechanics failed to comply wi

11
Kelley v. BLUE LINE CARRIERS, LLCgreen
gactapp · 2009 · cited in 1 Georgia opinions naming this issue, 2025–2025
2 sentences

2025Mgmt., 361 Ga. App. 311 , 318 (1) (b) ( 864 SE2d 140 ) (2021) (explaining that “[w]ithout a ruling by the trial court on its claim of spoliation, [appellant] cannot use the unresolved issue of spoliation to assert that genuine issues of material fact nonetheless exist”). 41 See Westmoreland, 362 Ga. App. at 122-23 (holding plaintiff, who was allegedly injured by glass bottles falling through package and onto floor, failed to establish spoliation claim that store’s failure to preserve packaging triggered rebuttable 22 To summarize, Johnson’s allegations that TICO’s mechanics failed to comply wi

2025Mgmt., 361 Ga. App. 311 , 318 (1) (b) ( 864 SE2d 140 ) (2021) (explaining that “[w]ithout a ruling by the trial court on its claim of spoliation, [appellant] cannot use the unresolved issue of spoliation to assert that genuine issues of material fact nonetheless exist”). 41 See Westmoreland, 362 Ga. App. at 122-23 (holding plaintiff, who was allegedly injured by glass bottles falling through package and onto floor, failed to establish spoliation claim that store’s failure to preserve packaging triggered rebuttable 22 To summarize, Johnson’s allegations that TICO’s mechanics failed to comply wi

11
Drew v. DeKalb Countygreen
ga · 1977 · cited in 1 Georgia opinions naming this issue, 2017–2017
11
Woods v. Brannengreen
ga · 1951 · cited in 1 Georgia opinions naming this issue, 2017–2017
1 sentence

2017Woods, 208 Ga. at 496 (1) (where a deed conveying a right-of-way to a railway company reserved to the landowner the right to cultivate the land up to the tracks “until . . . needed for railway purposes,” the landowner’s subsequent possession of land within the right-of-way was permissive and could not ripen into prescriptive title in the absence of an adverse claim and actual notice to the railway of that claim).

11
Henson v. Tuckergreen
gactapp · 2006 · cited in 1 Georgia opinions naming this issue, 2017–2017
11
Arnold v. Shackelfordgreen
ga · 1964 · cited in 1 Georgia opinions naming this issue, 2017–2017
11
McDonald v. Taylorgreen
ga · 1946 · cited in 1 Georgia opinions naming this issue, 2011–2011
11
Simmons v. Community Renewal & Redemption, LLCgreen
ga · 2009 · cited in 1 Georgia opinions naming this issue, 2011–2011
11
Holloway v. Woodsgreen
ga · 1942 · cited in 1 Georgia opinions naming this issue, 2008–2008
11
Sheffield v. Colliergreen
ga · 1847 · cited in 1 Georgia opinions naming this issue, 2001–2001
11
Mayor of Macon v. Franklingreen
· 1852 · cited in 1 Georgia opinions naming this issue, 2001–2001
11
Mathis v. Holcombgreen
ga · 1959 · cited in 1 Georgia opinions naming this issue, 2001–2001
11
Beavers v. Weatherlygreen
ga · 1983 · cited in 1 Georgia opinions naming this issue, 2001–2001
11
Cotton States Fertilizer Co. v. Childsgreen
ga · 1934 · cited in 1 Georgia opinions naming this issue, 1999–1999
11
Wallace v. Mizegreen
· 1922 · cited in 1 Georgia opinions naming this issue, 1998–1998
11
Trednick v. Kramergreen
gactapp · 1989 · cited in 1 Georgia opinions naming this issue, 1998–1998
11
Hodges v. Hodgesgreen
ga · 1957 · cited in 1 Georgia opinions naming this issue, 1998–1998
11
Whitworth v. Whitworthgreen
ga · 1974 · cited in 1 Georgia opinions naming this issue, 1998–1998
11
Tennessee, Alabama & Georgia Railway Co. v. Zugargreen
ga · 1942 · cited in 1 Georgia opinions naming this issue, 1983–1983
11
Barnett v. Hollidaygreen
ga · 1971 · cited in 1 Georgia opinions naming this issue, 1982–1982
11
Harris v. Mandevillegreen
ga · 1943 · cited in 1 Georgia opinions naming this issue, 1982–1982
11
Nassar v. Saltergreen
ga · 1957 · cited in 1 Georgia opinions naming this issue, 1982–1982
11
McDonough & Co. v. Martingreen
ga · 1892 · cited in 1 Georgia opinions naming this issue, 1980–1980
11
Brown v. Lawrencegreen
ga · 1949 · cited in 1 Georgia opinions naming this issue, 1978–1978
11
Hasty v. Wilsongreen
ga · 1967 · cited in 1 Georgia opinions naming this issue, 1977–1977
11
Roddy v. Coxgreen
ga · 1859 · cited in 1 Georgia opinions naming this issue, 1946–1946
11
Blount v. Beallgreen
· 1894 · cited in 1 Georgia opinions naming this issue, 1946–1946
11
Mitchell v. Guntergreen
ga · 1930 · cited in 1 Georgia opinions naming this issue, 1946–1946
11
Grant v. Hartgreen
ga · 1941 · cited in 1 Georgia opinions naming this issue, 1945–1945
11
Hadaway v. Hadawaygreen
ga · 1941 · cited in 1 Georgia opinions naming this issue, 1945–1945
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (40)

CaseCitedYears
Hamilton v. Mutual Benefit Life Insurance green
ga · 1898
2 sentences

1972Morgan v. Mitchell, 104 Ga. 596, 598 ( 30 SE 792 ).

1946Exclusive possession, therefore, by a cotenant alone will be presumed not an adverse holding, but simply one in support of the common title.” Morgan v. Mitchell, 104 Ga. 596, 598 ( 30 S. E. 792 ).

31946–1972
Dutton v. Faulk neutral
ga · 1925
2 sentences

1939Melson v. Leigh, 159 Ga. 683 ( 126 S. E. 718 ); Jay v. Whelchel, 78 Ga. 786 ( 3 S. E. 906 ).

1933Permissive possession can not be the foundation of a prescription, until an adverse claim and actual notice to the other party.” The principle stated in the sentence italicized was the basis of the decision in Melson v. Leigh, 159 Ga. 683 ( 126 S. E. 718 ), cited by counsel for plaintiff in error.

31933–1939
Erwin v. Brooke green
ga · 1925
2 sentences

1939Melson v. Leigh, 159 Ga. 683 ( 126 S. E. 718 ); Jay v. Whelchel, 78 Ga. 786 ( 3 S. E. 906 ).

1933Permissive possession can not be the foundation of a prescription, until an adverse claim and actual notice to the other party.” The principle stated in the sentence italicized was the basis of the decision in Melson v. Leigh, 159 Ga. 683 ( 126 S. E. 718 ), cited by counsel for plaintiff in error.

31933–1939
Young v. Durham green
gactapp · 1915
2 sentences

1974"Where a defendant in an action of trover admits in his plea or answer his possession of the property at the time of the action, under an adverse claim of title or right of possession, it is not necessary for the plaintiff to prove a demand and refusal...” Also see Young v. Durham, 15 Ga. App. 678 (5) ( 84 SE 165 ), which case is cited by the lower court.

1974"Where a defendant in an action of trover admits in his plea or answer his possession of the property at the time of the action, under an adverse claim of title or right of possession, it is not necessary for the plaintiff to prove a demand and refusal...” Also see Young v. Durham, 15 Ga. App. 678 (5) ( 84 SE 165 ), which case is cited by the lower court.

21922–1974
Bledsoe v. Willingham neutral
ga · 1879
2 sentences

1949While ordinarily prescription will not run against a remainderman out of possession during the occupancy of the estate by the life tenant ( Bledsoe v. Willingham , supra; Bull v. Walker , supra; Lamar v. Pearre , supra; Wallace v. Jones , supra; Seaboard Airline Ry. v. Holliday , supra), nevertheless where it appears that the adverse claim is based on a false, fraudulent, or forged deed, of which the remainderman has notice, equity requires that such remainderman shall proceed within a reasonable time to have such false, fraudulent, or forged deed removed as a cloud upon his title.

1949While ordinarily prescription will not run against a remainderman out of possession during the occupancy of the estate by the life tenant (Bledsoe v. Willingham, supra; Bull v. Walker, supra; Lamar v. Pearre, supra; Wallace v. Jones, supra; Seaboard Airline Ry. v. Holliday, supra), nevertheless where it appears that the adverse claim is based on a false, fraudulent, or forged deed, of which the remainderman has notice, equity requires that such remainderman shall proceed within a reasonable time to have such false, fraudulent, or forged deed removed as a cloud upon his title.

21949–1949
Bull v. Walker neutral
ga · 1884
2 sentences

1949While ordinarily prescription will not run against a remainderman out of possession during the occupancy of the estate by the life tenant ( Bledsoe v. Willingham , supra; Bull v. Walker , supra; Lamar v. Pearre , supra; Wallace v. Jones , supra; Seaboard Airline Ry. v. Holliday , supra), nevertheless where it appears that the adverse claim is based on a false, fraudulent, or forged deed, of which the remainderman has notice, equity requires that such remainderman shall proceed within a reasonable time to have such false, fraudulent, or forged deed removed as a cloud upon his title.

1949While ordinarily prescription will not run against a remainderman out of possession during the occupancy of the estate by the life tenant (Bledsoe v. Willingham, supra; Bull v. Walker, supra; Lamar v. Pearre, supra; Wallace v. Jones, supra; Seaboard Airline Ry. v. Holliday, supra), nevertheless where it appears that the adverse claim is based on a false, fraudulent, or forged deed, of which the remainderman has notice, equity requires that such remainderman shall proceed within a reasonable time to have such false, fraudulent, or forged deed removed as a cloud upon his title.

21949–1949
Frost v. Arnaud green
ga · 1915
2 sentences

1949Frost v. Arnaud, 144 Ga. 26 (2) ( 85 S. E. 1028 ); Hadden v. Thompson, 202 Ga. 74, 78 ( 42 S. E. 2d, 125 ).

1949Frost v. Arnaud, 144 Ga. 26 (2) ( 85 S. E. 1028 ); Hadden v. Thompson, 202 Ga. 74, 78 ( 42 S. E. 2d, 125 ).

21949–1949
Ward v. Parks green
ga · 1928
2 sentences

1946Ward v. Parks, 166 Ga. 149 (4b) ( 142 S. E. 690 ); Holley v. Hawley, 39 Vt. 525 ( 94 Am.

1946Ward v. Parks, 166 Ga. 149 (4b) ( 142 S. E. 690 ); Holley v. Hawley, 39 Vt. 525 ( 94 Am.

21946–1946
Holley v. Hawley neutral
vt · 1867
2 sentences

1946Ward v. Parks , 166 Ga. 149 (4b) ( 142 S.E. 690 ); Holley v. Hawley, 39 Vt. 525 ( 94 Am.

1946Ward v. Parks, 166 Ga. 149 (4b) ( 142 S. E. 690 ); Holley v. Hawley, 39 Vt. 525 ( 94 Am.

21946–1946
Richards v. Edwardy green
ga · 1912
2 sentences

1941Richards v. Edwardy, 138 Ga. 690 ( 16 S. E. 64 ); Hinesley v. Stewart, 139 Ga. 1 ( 16 S. E. 385 ); Hall v. Collier, 146 Ga. 815 ( 92 S. E. 536 ).

1927Richards v. Edwardy, 138 Ga. 690 ( 76 S. E. 64 ); Hinesley v. Stewart, 139 Ga. 7 ( 76 S. E. 385 ); Hall v. Collier, 146 Ga. 815 ( 92 S. E. 536 ).

21927–1941
Hall v. Collier green
ga · 1917
2 sentences

1941Richards v. Edwardy, 138 Ga. 690 ( 16 S. E. 64 ); Hinesley v. Stewart, 139 Ga. 1 ( 16 S. E. 385 ); Hall v. Collier, 146 Ga. 815 ( 92 S. E. 536 ).

1927Richards v. Edwardy, 138 Ga. 690 ( 76 S. E. 64 ); Hinesley v. Stewart, 139 Ga. 7 ( 76 S. E. 385 ); Hall v. Collier, 146 Ga. 815 ( 92 S. E. 536 ).

21927–1941
Hall v. Citizens Bank of Hazlehurst neutral
ga · 1917
2 sentences

1941Richards v. Edwardy, 138 Ga. 690 ( 16 S. E. 64 ); Hinesley v. Stewart, 139 Ga. 1 ( 16 S. E. 385 ); Hall v. Collier, 146 Ga. 815 ( 92 S. E. 536 ).

1927Richards v. Edwardy, 138 Ga. 690 ( 76 S. E. 64 ); Hinesley v. Stewart, 139 Ga. 7 ( 76 S. E. 385 ); Hall v. Collier, 146 Ga. 815 ( 92 S. E. 536 ).

21927–1941
Rucker v. Rucker green
ga · 1911
2 sentences

1938“Possession remaining with the grantor and never surrendered is held under the grantee, and is not adverse to his title; and neither prescription nor the statute of limitations is available as a defense to an action of ejectment founded on the deed.” Jay v. Whelchel, 78 Ga. 786, 789 ( 3 S. E. 906 ); Rucker v. Rucker, 136 Ga. 830 (2) ( 72 S. E. 241 ); Melson v. Leigh, 159 Ga. 683 ( 126 S. E. 718 ); Johnson v. Hume, 163 Ga. 867 ( 137 S. E. 56 ).

1938“Possession remaining with the grantor and never surrendered is held under the grantee, and is not adverse to his title; and neither prescription nor the statute of limitations is available as a defense to an action of ejectment founded on the deed.” Jay v. Whelchel, 78 Ga. 786, 789 ( 3 S. E. 906 ); Rucker v. Rucker, 136 Ga. 830 (2) ( 72 S. E. 241 ); Melson v. Leigh, 159 Ga. 683 ( 126 S. E. 718 ); Johnson v. Hume, 163 Ga. 867 ( 137 S. E. 56 ).

21930–1938
Pearson v. Jones green
gactapp · 1916
2 sentences

1937“Where the defendant is in possession at the time suit is entered, proof of demand and refusal is necessary only to save the plaintiff the costs of court in case the defendant should disclaim title to the property.” Pearson v. Jones, 18 Ga. App. 448 (4-a) ( 89 S. E. 536 ).

1922Civil Code (1910), § 4483; Muse v. Wright, 103 Ga. 783, 784 ( 30 S. E. 662 ); Moore v. Ramsey, 144 Ga. 118 ( 86 S. E. 219 ); Young v. Durham, 15 Ga. App. 678 (5) ( 84 S. E. 165 ); Pearson v. Jones, 18 Ga. App. 448 ( 89 S. E. 536 ); Collins v. Hilton, 27 Ga. App. 439 ( 108 S. E. 824 ). 2.

21922–1937
Lowther v. State green
gactapp · 1916
2 sentences

1937“Where the defendant is in possession at the time suit is entered, proof of demand and refusal is necessary only to save the plaintiff the costs of court in case the defendant should disclaim title to the property.” Pearson v. Jones, 18 Ga. App. 448 (4-a) ( 89 S. E. 536 ).

1922Civil Code (1910), § 4483; Muse v. Wright, 103 Ga. 783, 784 ( 30 S. E. 662 ); Moore v. Ramsey, 144 Ga. 118 ( 86 S. E. 219 ); Young v. Durham, 15 Ga. App. 678 (5) ( 84 S. E. 165 ); Pearson v. Jones, 18 Ga. App. 448 ( 89 S. E. 536 ); Collins v. Hilton, 27 Ga. App. 439 ( 108 S. E. 824 ). 2.

21922–1937
Smith v. Commercial Credit Co. green
gactapp · 1922
2 sentences

1937“Where a defendant in an action of trover admits in his plea or answer his possession of the property at the time of the action, under an adverse claim of title or right of possession, it is not necessary for the plaintiff to prove a demand and refusal or any other conversion of the property.” Smith v. Commercial Credit Co., 28 Ga. App. 403 ( 111 S. E. 821 ); Code, § 107-101.

1923“Where a defendant in an action of trover admits in his plea or answer his possession of the property at the time of the action, under an adverse claim of title or right of possession, it is not necessary for the plaintiff to prove a demand and refusal or any other conversion of the property.” Smith v. Commercial Credit Co., 28 Ga. App. 403 (1) ( 111 S. E. 821 ), and cases cited. 2.

21923–1937
Citizens First National Bank v. Wilson green
gactapp · 1922
2 sentences

1937“Where a defendant in an action of trover admits in his plea or answer his possession of the property at the time of the action, under an adverse claim of title or right of possession, it is not necessary for the plaintiff to prove a demand and refusal or any other conversion of the property.” Smith v. Commercial Credit Co., 28 Ga. App. 403 ( 111 S. E. 821 ); Code, § 107-101.

1923“Where a defendant in an action of trover admits in his plea or answer his possession of the property at the time of the action, under an adverse claim of title or right of possession, it is not necessary for the plaintiff to prove a demand and refusal or any other conversion of the property.” Smith v. Commercial Credit Co., 28 Ga. App. 403 (1) ( 111 S. E. 821 ), and cases cited. 2.

21923–1937
Gordon v. Georgia Kraft Company green
ga · 1962
12008–2008
Harper v. Durden green
ga · 1933
11990–1990
Bowles v. White neutral
ga · 1950
11990–1990
Board of Trustees of Employees' Retirement System v. Kenworthy green
ga · 1984
11990–1990
Greer v. Piedmont Realty Investments, Inc. neutral
ga · 1982
11989–1989
May v. Sorrell green
ga · 1922
11980–1980
Jones v. State green
ga · 1922
11980–1980
Fender v. Gardner neutral
ga · 1922
11978–1978
Blackwell v. Partridge green
ga · 1923
11978–1978
Bennett v. Davis green
ga · 1946
11965–1965
Hardin v. Snow neutral
ga · 1946
11965–1965
Garner v. Lankford green
ga · 1917
11958–1958
Citizens & Southern National Bank v. Ellis green
ga · 1931
11958–1958
Hicks v. Webb green
ga · 1906
11950–1950
Wells v. Walker neutral
ga · 1859
11949–1949
Robson v. Harris green
· 1888
11947–1947
Anderson v. Caldwell green
gactapp · 1942
11947–1947
Denham v. Holeman green
ga · 1858
11944–1944
Roe v. Doe ex dem. Morrison neutral
ga · 1860
11944–1944
Graham v. Mitchell neutral
ga · 1886
11944–1944
Clark v. White green
ga · 1904
11944–1944
Bradley v. Shelton green
ga · 1940
11944–1944
Kirschner v. Western & Atlantic Railroad neutral
ga · 1881
11944–1944

Statutes the citing opinions construe

GA § 44-9-59 (5) GA § 9-11-56 (5) GA § 44-11-9 (4) GA § 44-5-161 (4) GA § 44-9-1 (4) GA § 44-9-54 (4) GA § 44-5-163 (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 297 (1857–2026) CA 138 (1870–2025) LA 118 (1858–2025) MS 87 (1818–2025) NY 87 (1848–2025) MO 75 (1867–2024) GA 73 (1897–2025) CT 68 (1909–2024) AR 57 (1853–2025) OR 57 (1892–2025) AL 55 (1842–2025) IL 45 (1890–2026) TN 37 (1899–2024) OK 36 (1912–2024) KY 33 (1817–2025) PA 33 (1835–2025) OH 32 (1880–2026) NH 31 (1916–2025) VA 31 (1819–2026) FL 30 (1894–2025) MT 30 (1883–2018) NC 30 (1889–2018) WA 27 (1895–2026) AZ 27 (1936–2024) MI 26 (1873–2024) WY 24 (1895–2025) MD 23 (1907–2022) CO 22 (1890–2025) IN 22 (1862–2025) ID 21 (1893–2025) WV 19 (1881–2025) WI 19 (1900–2026) MA 17 (1898–2021) MN 17 (1883–2015) UT 16 (1887–2025) HI 16 (1902–2025) NM 15 (1885–2011) ME 15 (1847–2008) KS 15 (1883–2026) IA 14 (1861–2020) NJ 11 (1879–2011) SC 10 (1900–2021) NV 10 (1913–2022) NE 10 (1896–2020) VT 9 (1838–2025) ND 7 (1906–2018) SD 5 (1910–2020) DE 3 (1954–1986) PR 3 (1923–1971) RI 3 (2003–2011) AK 2 (1974–1995) DC 2 (1978–1992)

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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