May Private Party Take Title to Land Owned by Park District Via ‘Adverse Possession’?
Richard Houck et al. v. Board of Park Commissioners, Huron County Park District, et al., Case no. 2006-1262 6th District Court of Appeals (Huron County) ISSUES: • May a private party obtain legal title to land owned by a park district established under R.C. Chapter 1545 by means of adverse possession? • If a claim of adverse possession may be asserted against land owned by a park district, does the 21-year time of possession required to establish such a claim continue to accrue after the date on which the park district assumed ownership of the disputed land? BACKGROUND: Under certain conditions, the common law doctrine of “adverse possession” allows a party to claim legal title to a parcel of land by occupying that land without the permission of the titled owner and making “continuous, exclusive, hostile, open and notorious” use of it for 21 years. In this case, Richard Hauck and several other private landowners in Huron County filed a court action in 2003 seeking to establish title in
