Am. Trading Real Estate Props., Inc. v. Trumbull
In Am. Trading Real Estate Props., Inc. v. Trumbull, 574 A.2d 796, 800-02 (Conn. 1990), the Supreme Court of Connecticut explained that while "title to realty held in fee by a state or any of its subdivisions for a public use cannot be acquired by adverse possession, a public entity may claim immunity from adverse possession ... only to the extent that the property against which a claim has been asserted is held for public use." Id. at 800.
Therefore, where a public entity holds land for a proprietary use or where, by virtue of the use, "the public is given no beneficial rights, to be enjoyed presently or in the future," no immunity to adverse possession may be claimed by a public entity. Id. at 801.