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Illinois Compiled Statutes

735 ILCS 5/13-101 (2026)

Twenty years - Recovery of land

✓ current as of May 2026
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(735 ILCS 5/13-101) (from Ch. 110, par. 13-101)
    Sec. 13-101. Twenty years - Recovery of land. No person shall commence an action for the recovery of lands, nor make an entry thereon, unless within 20 years after the right to bring such action or make such entry first accrued, or within 20 years after he, she or those from, by, or under whom he or she claims, have acquired title or possession of the premises, except as provided in Sections 13-102 through 13-122 of this Act.
(Source: P.A. 82-280.)

    
Notes of Decisions
Cited in 37 cases (12 in the last 5 years), 1993–2026 · leading case: Super Mix of Wisconsin, Inc. v. Nat. Gas Pipeline Co. of Am., LLC, 2020 IL App (2d) 190034 (Ill. App. Ct. 2021).
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Super Mix of Wisconsin, Inc. v. Nat. Gas Pipeline Co. of Am., LLC, 2020 IL App (2d) 190034 (Ill. App. Ct. 2021). · cites it 2× “Defendant argued that count II was barred by the 20-year statute of limitations that applies to claims for inverse condemnation (735 ILCS 5/13-101 (West 2018)). -3- ¶ 15 Plaintiffs responded that neither claim was time-barred because plaintiffs were claiming present damages from…”
Hoch v. Boehme, 2013 IL App (2d) 120664 (Ill. App. Ct. 2013). · cites it 3× “See 735 ILCS 5/13-101 (West 2010). -3- ¶8 In their reply in support of the motion to dismiss, the Schmidts expanded their argument to dispute as well the Hochs’ claim to title based on a deed.”
People v. Moore, 2021 IL App (1st) 172811 (Ill. App. Ct. 2021). “Johnson, 2014 IL App (4th) 130923, ¶ 37 ); see 735 ILCS 5/13-101 (West 2012). Under the second approach, “a claimant can show actual and adverse possession of lands for seven years, 56 1-17-2811 contemporaneously with paying taxes under color of title.”
Mazal v. Arias, 2019 IL App (1st) 190660 (Ill. App. Ct. 2019). “Defendants argued that the 16-foot strip was statutorily dedicated to the Village of Lincolnwood for use as a public alleyway and, as a matter of law, the Village of Lincolnwood was not subject to the 20-year limitations period on the recovery of lands embodied in section 13-101…”
Relf v. Shatayeva, 2013 IL 114925 (Ill. 2013). “¶ 24 Section 13-209 appears in article XIII of the Code of Civil Procedure (735 ILCS 5/13-101 et seq. (West 2010)), which deals with limitations on actions.”
Newell Co. v. Petersen, 758 N.E.2d 903 (Ill. App. Ct. 2001). “See 735 ILCS 5/13-101 et seq. (West 2000). Courts are therefore left with the choice of watching the clock or inquiring into the purpose of the statute.”
Brandhorst v. Johnson, 2014 IL App (4th) 130923 (Ill. App. Ct. 2014). “We address defendants’ contentions in turn. ¶ 35 A. The Trial Court’s Adverse Possession Finding ¶ 36 1.”
People v. Brown, 2017 IL App (1st) 142877 (Ill. App. Ct. 2017). “Johnson, 2014 IL App (4th) 130923, ¶ 37 ; 735 ILCS 5/13-101 (West 2012). Alternatively, a claimant can show actual and adverse possession of lands for seven years, contemporaneously with paying taxes under color of title.”
Relf v. Shatayeva, 2013 IL 114925 (Ill. 2013). “-6- ¶ 24 Section 13-209 appears in article XIII of the Code of Civil Procedure (735 ILCS 5/13-101 et seq. (West 2010)), which deals with limitations on actions.”
Dotson v. Former Shareholders of Abraham Lincoln Land & Cattle Co., 773 N.E.2d 792 (Ill. App. Ct. 2002). “In addition to the cases cited by plaintiff, we find persuasive the similarity between adverse possession cases (see 735 ILCS 5/13-101 (West 1996)) and those brought under section 13-110.”
Davidson v. Perry, 898 N.E.2d 785 (Ill. App. Ct. 2008). “Adverse Possession To establish title by adverse possession under the 20-year statute (735 ILCS 5/13-101 (West 2006)), the party asserting adverse possession must establish possession of the property for the entire statutory period, and that possession must have been "(1)…”
In re Est. of Cargola, 2017 IL App (1st) 151823 (Ill. App. Ct. 2017). · cites it 2× “Knorrek argued that for a period in excess of 20 years, 1991 through 2014, she had actual possession of the property openly, continuously, adversely, and under a claim of title which is inconsistent with that of Cargola, satisfying the elements of adverse possession pursuant to…”
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