In 1973, William Arnholt and his then wife, Marie Arnholt, purchased a parcel of land abutting a stream. They remained there until 1993, when they were divorced. Pursuant to their divorce decree, Marie continued to reside in the home until 1995, at which time William took possession. Since the purchase of the land in 1973, William had treated a barbed-wire fence on the other side of the stream as his property’s boundary line.
Over the years, he had planted as many as 150 trees on the sides of the stream and buttressed the stream banks with bricks and tiles. He had also begun mowing the area on the opposite side of the stream and storing materials and automobiles not far from the stream. Carlisle is the owner of an adjoining parcel on which the disputed area (the area between the stream and the fence) sits. After disputes between Carlisle and Arnholt arose, Arnholt filed a complaint seeking title to the disputed property on the grounds of adverse possession.
Did Arnholt meet all of the requirements of adverse possession?
[Arnholt v. Carlisle, 2011 WL 2436590 (Ohio Ct. App. June 6, 2011).]