Maine Revised Statutes

Me. Rev. Stat. tit. 14, § 6651 (2026)

Summary proceedings

✓ current as of May 2026

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A person in possession of real property, claiming an estate of freehold therein or an unexpired term of not less than 10 years, or a person who has conveyed such property or any interest therein with covenants of title or warranty, upon which he may be liable, may, if he or those under whom he claims or those claiming under him have been in uninterrupted possession of such property for 4 years or more, bring an action in the Superior Court, or in the District Court in the county or district respectively in which said real property lies, setting forth his estate, stating the source of his title, describing the premises, and averring that an apprehension exists that persons named in the complaint, or persons unknown claiming as heirs, devisees or assigns, or in any other way, by, through or under a person or persons named in the complaint, claim or may claim some right, title or interest in the premises adverse to his said estate; and that such apprehension creates a cloud upon the title and depreciates the market value of the property; and praying that such persons be summoned to show cause why they should not bring an action to try their title to the described premises. If any such supposed claimants are unknown, the plaintiff or his attorney shall so allege under oath, but the truth of the allegation shall not after decree has been filed be denied for the purpose of defeating the title established thereby. A person in the enjoyment of an easement is in possession of real property within the meaning and for the purposes of this section. [PL 1971, c. 117, §2 (AMD).]

SECTION HISTORY

PL 1971, c. 117, §2 (AMD).

Notes of Decisions

Cited in 34 cases (5 in the last 5 years), 1976–2023 · leading case: James N. Levis v. Gustav Konitzky, 2016 ME 167 (Me. 2016).

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James N. Levis v. Gustav Konitzky, 2016 ME 167 (Me. 2016). “14 M.R.S. § 6651; see Chickering v. Yates, 420 A.”

Lewien v. Cohen, 432 A.2d 800 (Me. 1981). · cites it 2× “2d 667 (1980), involved the peculiar features of Maine’s statutory quiet title proceedings under 14 M.R.S.A. § 6651 and 14 M.R.S.A. § 6655.”

Johnson v. Town of Dedham, 490 A.2d 1187 (Me. 1985). · cites it 2× “Dedham argues in the alternative that the Superior Court erred in failing to require that Johnson prove uninterrupted possession of the land by himself or those under whom he claims for at least four years as required by 14 M.R.S.A. § 6651 (1980). Because Dedham first raised…”

Glidden v. Belden, 684 A.2d 1306 (Me. 1996). “(citing 14 M.R.S.A. §§ 6651 et seq. (1980 & Supp.”

Chickering v. Yates, 420 A.2d 1219 (Me. 1980). · cites it 2× “Mabel Chickering appeals from an order of the Superior Court denying her the relief she requested under 14 M.R.S.A. §§ 6651 — 54 (Summary Proceedings to Quiet Title) and dismissing her complaint.”

Hamlin v. Niedner, 2008 ME 130 (Me. 2008). “CASE HISTORY [¶ 2] In February 2007, David Hamlin filed a complaint to quiet title pursuant to *253 14 M.R.S. § 6651 (2007) and remove any cloud from the title to his land and a portion of land deeded to the Niedners but claimed by Hamlin.”

Bigney v. Blanchard, 430 A.2d 839 (Me. 1981). “Bigney, pursuant to 14 M.R.S.A. § 6651 et seq. (1980), to quiet title to certain real estate situated on the easterly side of Main Street in Greenville and appearing as an unnamed street on the Oakes plan and survey, so-called, made in 1881, recorded in Piscataquis Registry of…”

Est. of Stone v. Hanson, 621 A.2d 852 (Me. 1993). “See 14 M.R.S.A. § 6651 (1980). The matter was removed to the Superior Court.”

McGrath v. Hills, 662 A.2d 215 (Me. 1995). “14 M.R.S.A. § 6651 (1980) provides in pertinent part: A person in possession of real property, claiming an estate of freehold therein or an unexpired term of not less than 10 years, or a person who has conveyed such property or any interest therein with covenants of title or…”

Sprague Corp. v. Sprague, 855 F. Supp. 423 (D. Me. 1994). “The counts in Plaintiffs' Amended Complaint are as follows: Count I requests a judgment to quiet title pursuant to section 6651 of the Maine Revised Statutes Annotated, 14 M.R.S.A. § 6651; Count II requests that the 1941 deed, in which Sprague Corporation conveyed Ram’s Head to…”

Thornton v. Est. of Cressey, 413 A.2d 540 (Me. 1980). “” On September 12,1975 plaintiffs instituted the instant action in the District Court, District Ten, Division of Western York, to quiet and to establish title, pursuant to 14 M.R.S.A. § 6651. In October, 1975, on motion of one of the defendants, the action was removed to the…”

Donaghy v. Leighton, 351 A.2d 125 (Me. 1976). “This appeal results from a proceeding to quiet title (14 M.R.S.A. § 6651) to which defendant Leighton counterclaimed asking that title be confirmed in him.”

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