Emerson v. Maine Rural Missions Ass’n, 560 A.2d 1 (Me. 1989)

In Emerson, the Maine Supreme Judicial Court affirmed the trial court’s ruling that the Emersons had acquired title to a disputed parcel of land by adverse possession.

Background:

  • The Emersons purchased property on Essex Street in Bangor in the early 1960s.
  • In 1963, they sold part of their land to Maine Rural Missions (MRM).
  • In 1986, they discovered that MRM claimed title to a parcel the Emersons believed they still owned and had never intended to sell.
  • The Emersons sued to quiet title.

Holding:

The Court upheld the Superior Court’s ruling that the Emersons had established title to the disputed parcel by adverse possession.

Legal Findings:

The Court found credible evidence that the Emersons met all the elements required for adverse possession:

  1. Actual possession – They filled the land, extended their driveway, built a garage, planted gardens and trees, stored vehicles, and used the land for recreation.
  2. Open and notorious – Their activities were visible and obvious, sufficient to put a reasonable landowner on notice.
  3. Continuous for 20 years – Use began in the early 1960s and continued without interruption.
  4. Hostile under a claim of right – Despite possible mistake, the Emersons intended to claim the land regardless of legal ownership.
  5. Exclusive use – No one from MRM ever used or challenged the Emersons’ use during the relevant period.

Conclusion:

Judgment affirmed. The Emersons obtained title to the full disputed area by adverse possession.

Summary by ChatGPT