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6 Wisconsin opinions name it 2 courts 1901–2025 2 in the last five years
The cases below were cited by Wisconsin 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.
| Case | Followed | Cited |
|---|---|---|
Burkhardt v. Smithgreen2 sentences2025STAT. § 893.25, “if the cultivation or improvement in relation to the nature of the use in the area indicates the boundaries of the adverse claim and is usual under the circumstances, such use is sufficient and considered actual occupancy under the statute.” Burkhardt, 17 Wis. 2d at 134, 138 (discussing WIS. 1998The supreme court has held that using property for "the ordinary use to which the land is capable and such as an owner would make of it" in the usual course *422 of events — and in a way that indicates the boundaries of the adverse claim — provides sufficient notice of actual and exclusive adverse possession, Burkhardt v. Smith, 17 Wis. 2d 132, 138 , 115 N.W.2d 540, 544 (1962); and we believe Thorson did just that. | 2 | 2 |
Kruckenberg v. Krukargreen2 sentences2023See Kruckenberg v. Krukar, 2017 WI App 70, ¶12 , 378 Wis. 2d 314 , 903 N.W.2d 164 (“All that is required to fulfil the substantial enclosure requirement is something that indicates the boundaries of the adverse claim.” 25 (citing WIS JI—CIVIL 8060 (“The requirement of ‘substantial enclosure’ must alert a reasonable person of a dispute over the land.”))). 2023See Kruckenberg v. Krukar, 2017 WI App 70, ¶12 , 378 Wis. 2d 314 , 903 N.W.2d 164 (“All that is required to fulfil the substantial enclosure requirement is something that indicates the boundaries of the adverse claim.” 25 (citing WIS JI—CIVIL 8060 (“The requirement of ‘substantial enclosure’ must alert a reasonable person of a dispute over the land.”))). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Wisconsin. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Sage v. Morosick
neutral
2 sentences2010The plaintiffs contend that the approximately 200 feet of man-made ditch constitutes an enclosure at least as substantial as the "mere furrow" referred to in Illinois Steel Co. in a passage relied on in Klinefelter : An inclosure having no purpose of physical exclusion of outside interferences — a mere furrow turned with a plow around the land (Sage v. Morosick, 69 Minn. 167 ) [ 71 N.W. 930 (1897)], or a line marked by cutting away the brush (Worthley v. Burbanks, 146 Ind. 534 ) [ 45 N.E. 779 (1897)], or a fence opened so as to admit outside disturbers (Sauers v. Giddings, 90 Mich. 50 ) [ 51 N 2010The plaintiffs contend that the approximately 200 feet of man-made ditch constitutes an enclosure at least as substantial as the "mere furrow" referred to in Illinois Steel Co. in a passage relied on in Klinefelter : An inclosure having no purpose of physical exclusion of outside interferences — a mere furrow turned with a plow around the land (Sage v. Morosick, 69 Minn. 167 ) [ 71 N.W. 930 (1897)], or a line marked by cutting away the brush (Worthley v. Burbanks, 146 Ind. 534 ) [ 45 N.E. 779 (1897)], or a fence opened so as to admit outside disturbers (Sauers v. Giddings, 90 Mich. 50 ) [ 51 N | 3 | 1901–2010 |
Worthley v. Burbanks
green
2 sentences2010The plaintiffs contend that the approximately 200 feet of man-made ditch constitutes an enclosure at least as substantial as the "mere furrow" referred to in Illinois Steel Co. in a passage relied on in Klinefelter : An inclosure having no purpose of physical exclusion of outside interferences — a mere furrow turned with a plow around the land (Sage v. Morosick, 69 Minn. 167 ) [ 71 N.W. 930 (1897)], or a line marked by cutting away the brush (Worthley v. Burbanks, 146 Ind. 534 ) [ 45 N.E. 779 (1897)], or a fence opened so as to admit outside disturbers (Sauers v. Giddings, 90 Mich. 50 ) [ 51 N 2010The plaintiffs contend that the approximately 200 feet of man-made ditch constitutes an enclosure at least as substantial as the "mere furrow" referred to in Illinois Steel Co. in a passage relied on in Klinefelter : An inclosure having no purpose of physical exclusion of outside interferences — a mere furrow turned with a plow around the land (Sage v. Morosick, 69 Minn. 167 ) [ 71 N.W. 930 (1897)], or a line marked by cutting away the brush (Worthley v. Burbanks, 146 Ind. 534 ) [ 45 N.E. 779 (1897)], or a fence opened so as to admit outside disturbers (Sauers v. Giddings, 90 Mich. 50 ) [ 51 N | 3 | 1901–2010 |
Sauers v. Giddings
neutral
2 sentences2010The plaintiffs contend that the approximately 200 feet of man-made ditch constitutes an enclosure at least as substantial as the "mere furrow" referred to in Illinois Steel Co. in a passage relied on in Klinefelter : An inclosure having no purpose of physical exclusion of outside interferences — a mere furrow turned with a plow around the land (Sage v. Morosick, 69 Minn. 167 ) [ 71 N.W. 930 (1897)], or a line marked by cutting away the brush (Worthley v. Burbanks, 146 Ind. 534 ) [ 45 N.E. 779 (1897)], or a fence opened so as to admit outside disturbers (Sauers v. Giddings, 90 Mich. 50 ) [ 51 N 1991In Illinois Steel Co. v. Bilot, 109 Wis. 418, 446 , 85 N.W. 402 , 408 (1901), the supreme court explained the purpose of the "substantial enclosure" requirement: An inclosure having no purpose of physical exclusion of outside interferences — a mere furrow turned with a plow around the land (Sage v. Morosick, 69 Minn. 167 ), or a line marked by cutting away the brush (Worthley v. Burbanks, 146 Ind. 534 ), or a fence opened so as to admit outside disturbers (Sauers v. Giddings, 90 Mich. 50 ), — may be sufficient under the *35 circumstances to indicate, as a matter of fact, the boundaries of the | 3 | 1901–2010 |
Illinois Steel Co. v. Bilot
green
2 sentences2010Klinefelter, 161 Wis. 2d at 34 -35 (quoting Illinois Steel Co., 109 Wis. at 446 ) (emphasis added). ¶ 32. 1991In Illinois Steel Co. v. Bilot, 109 Wis. 418, 446 , 85 N.W. 402 , 408 (1901), the supreme court explained the purpose of the "substantial enclosure" requirement: An inclosure having no purpose of physical exclusion of outside interferences — a mere furrow turned with a plow around the land (Sage v. Morosick, 69 Minn. 167 ), or a line marked by cutting away the brush (Worthley v. Burbanks, 146 Ind. 534 ), or a fence opened so as to admit outside disturbers (Sauers v. Giddings, 90 Mich. 50 ), — may be sufficient under the *35 circumstances to indicate, as a matter of fact, the boundaries of the | 2 | 1991–2010 |
Klinefelter v. Dutch
green
1 sentence2010Klinefelter, 161 Wis. 2d at 34 -35 (quoting Illinois Steel Co., 109 Wis. at 446 ) (emphasis added). ¶ 32. | 1 | 2010–2010 |
Wood v. Michigan Air Line Railroad
neutral
1 sentence2010The plaintiffs contend that the approximately 200 feet of man-made ditch constitutes an enclosure at least as substantial as the "mere furrow" referred to in Illinois Steel Co. in a passage relied on in Klinefelter : An inclosure having no purpose of physical exclusion of outside interferences — a mere furrow turned with a plow around the land (Sage v. Morosick, 69 Minn. 167 ) [ 71 N.W. 930 (1897)], or a line marked by cutting away the brush (Worthley v. Burbanks, 146 Ind. 534 ) [ 45 N.E. 779 (1897)], or a fence opened so as to admit outside disturbers (Sauers v. Giddings, 90 Mich. 50 ) [ 51 N | 1 | 2010–2010 |
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.
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.