ITT Rayonier Inc. v. Bell
Supreme Court of Washington
724 P.2d 6 (1989)
Bell (defendant) bought a boathouse in 1972 and used adjacent land owned by ITT Rayonier (plaintiff) to moor the boathouse and build a sauna, outhouse, and shed, admitting he knew the land was not his and never erecting fences or no-trespassing signs; two other families similarly used the same land for their own outhouses and minor structures. ITT sued to quiet title and eject Bell, and the trial court found no adverse possession because Bell did not hold the land exclusively, while the Court of Appeals affirmed and separately held Bell also lacked a good-faith claim of right.
Whether subjective belief in one's claim of right is necessary to acquire title by adverse possession, and whether an adverse possessor must hold land exclusively to the exclusion of others.