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Howard v. Kunto

Washington Court of Appeals

477 P.2d 210 (1970)

Relevant factsFree

A decades-old surveying error meant that a chain of deeds, including one eventually conveyed to Kunto (defendant), described land different from what each successive owner actually occupied and improved (including a dock Kunto's predecessor built); when Howard (plaintiff) discovered the error via a 1960 survey and arranged deed swaps with a neighbor to obtain record title to the land Kunto occupied, he sued to quiet title, and the trial court found Kunto - who had personally occupied the land less than a year - hadn't satisfied adverse possession's time requirement.

IssueFree

Whether using property only as a summer home constitutes sufficiently uninterrupted possession for adverse possession, and whether a claimant may tack a predecessor's occupancy time onto his own to satisfy the statutory period.

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