Gruebele v. Geringer
North Dakota Supreme Court
640 N.W.2d 454 (2002)
The garage straddling two adjacent tracts was shared by permission starting in 1975, when Tract 2's owner allowed Tract 1's owner to use it, and successive owners of both tracts continued that arrangement. The Gruebeles (plaintiffs), who bought Tract 2 in 1994, stored their belongings in the garage until Geringer (defendant) bought Tract 1 in 1996, at which point the Gruebeles removed their property and told Geringer the garage sat on the property line and needed to move. The Gruebeles then sued to quiet title, and Geringer claimed ownership by adverse possession; the trial court found he had not shown exclusive, continuous possession, and quieted title against him.
Whether a claimant must show actual, visible, continuous, notorious, distinct, and hostile possession for 21 years to establish adverse possession in North Dakota.