Massachusetts General Laws

Mass. Gen. Laws ch. 260, § 21 (2026)

Recovery of land

✓ current as of July 2026

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Section 21. An action for the recovery of land shall be commenced, or an entry made thereon, only within twenty years after the right of action or of entry first accrued, or within twenty years after the demandant or the person making the entry, or those under whom they claim, have been seized or possessed of the premises; provided, however, that this section shall not bar an action by or on behalf of a nonprofit land conservation corporation or trust for the recovery of land or interests in land held for conservation, parks, recreation, water protection or wildlife protection purposes.

Notes of Decisions

Cited in 45 cases (7 in the last 5 years), 1961–2025 · leading case: Beaconsfield Towne House Condo. Trust v. Zussman, 517 N.E.2d 816 (Mass. 1988).

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Beaconsfield Towne House Condo. Trust v. Zussman, 517 N.E.2d 816 (Mass. 1988). · cites it 10× “We agree with the plaintiff that the governing statute of limitations is G.L.c. 260, § 21 (1986 ed.), providing that actions to recover land must be commenced within twenty years after the cause of action accrues.”

White v. Hartigan, 464 Mass. 400 (Mass. 2013). · cites it 2× “783, 783 (1959); G. L. c. 260, § 21. It is the claimant’s burden to satisfy each of these elements.”

Sea Pines Condo. III Ass'n v. Steffens, 814 N.E.2d 752 (Mass. App. Ct. 2004). · cites it 2× “See G.L. c. 260, § 21. “Acts of possession which are ‘few, intermittent and equivocal’ [are insufficient to] constitute adverse possession.”

Kendall v. Selvaggio, 602 N.E.2d 206 (Mass. 1992). “G. L. c. 260, §§ 21, 22 (1990 ed.). Witnesses testified at trial that the defendants’ use of the land to maintain a fence was actual, open, notorious, exclusive, and continuous from approximately 1960 to 1983.”

Lawrence v. Town of Concord, 788 N.E.2d 546 (Mass. 2003). “G. L. c. 260, § 21. The burden of proving adverse possession is on the person claiming title thereby and “extends to all of the necessary elements of such possession.”

Hendrickson v. Sears, 310 N.E.2d 131 (Mass. 1974). “Suffice it that in matters affecting real estate titles the Legislature has commonly employed periods of twenty or thirty years, well beyond the period involved here.”

Dorothy Ann Wilson, Etc. v. Hammer Holdings, Inc., Dorothy Ann Wilson v. Hammer Holdings, Inc., 850 F.2d 3 (1st Cir. 1988). “See Mass.Gen.Laws Ann. ch. 260, § 21. In sum, then, we conclude that the Wil-sons’ cause of action for breach of a warranty of authenticity does not fall within the exception to section 2-725(2), and therefore accrued at the time of sale in 1961.”

In Re Colarusso, 295 B.R. 166 (1st Cir. BAP 2003). “Recovery of Land An action for the recovery of land shall be commenced, or an entry made thereon, only within twenty years after the right of action or of entry first accrued, or within twenty years after the defendant or the person making the entry, or those under whom they…”

Whitehouse v. Town of Sherborn, 419 N.E.2d 293 (Mass. App. Ct. 1981). “They ask us to hold that the town could acquire title only by adverse possession, and that their action is timely under the twenty-year limitations period provided by G. L. c. 260, § 21. 6 The defendants maintain, on the other hand, that the action is barred by the statutes of…”

Peck v. Bigelow, 613 N.E.2d 134 (Mass. App. Ct. 1993). “And see G. L. c. 260, §§ 21, 22. 5 A neighbor testified to a conversation with the defendant, after Peck’s lot was offered for sale, in which the defendant proposed to split the purchase price of the lot with him so that they might keep undesirable individuals out of their…”

Hornig v. Hornig, 374 N.E.2d 289 (Mass. App. Ct. 1978). “The first question argued by the parties in their briefs is whether the applicable period of limitations is the twenty-year period found in G. L. c. 260, § 21, as the plaintiff contends (see Hill v.”

CBK Brook House I Ltd. P'ship v. Berlin, 834 N.E.2d 1251 (Mass. App. Ct. 2005). “The judge determined BHC’s claims were “essentially contractual in nature” and were not for the purpose of recovery of land (so as to allow application of the twenty-year limitations period found in G. L. c. 260, § 21). There was no error in so ruling.”

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