Strong v. Strong

In Strong v. Strong, 128 Tex. 470, 98 S.W.2d 346, 350 (Tex. 1936), the Court described the kind of possession sufficient to give constructive notice as "consisting of open, visible, and unequivocal acts of occupancy in their nature referable to exclusive dominion over the property, sufficient upon observation to put an intending purchaser on inquiry as to the rights of such possessor. " Strong, 98 S.W.2d at 350. Possession that meets these requirements--visible, open, exclusive, and unequivocal possession--affords notice of title equivalent to the constructive notice deed registration affords. Strong, 98 S.W.2d at 348. However, the Court also held that "ambiguous or equivocal possession which may appear subservient or attributable to the possession of the holder of the legal title is not sufficiently indicative of ownership to impute notice as a matter of law of the unrecorded rights of such possessor." Strong, 98 S.W.2d at 350.