Blickenstaff v. Bromley

In Blickenstaff v. Bromley, 243 Md. 164, 170, 220 A.2d 558 (1966) the land in issue was a "small parcel" of "scrubby, brush land" adjacent to a farm. Id. at 166-69. The Blickenstaffs, who claimed title by adverse possession, "cleared brush . . . cut bean poles . . . felled large trees . . . and . . . planted and maintained a flower bed" on that property. Id. at 172. The circuit court did not find that they were entitled to the disputed land, based on adverse possession. The Court of Appeals reversed. Id. at 174. Noting that "there was never an assertion of ownership of the subject parcel by title owners," id. at 172, the Court concluded that the acts of the adverse possessors, "when the character and location of the small parcel are considered, were sufficient to comport with the ordinary management of similar lands by owners." Id. Therefore, it reversed the circuit court and held that the Blickenstaffs satisfied all the elements to obtain title by adverse possession. Id. at 174. In Blickenstaff, 243 Md. at 171, the Court explained: "It is sufficient if the acts of ownership are of such a character as to openly and publicly indicate an assumed control or use such as is consistent with the character of the premises in question. The standard to be applied to any particular tract of land is whether the possession comports with the ordinary management of similar lands by their owners, and if so, it furnishes satisfactory evidence of adverse possession."