In Bagley v. Moxley (1990) 407 Mass. 633 555 N.E.2d 229, the plaintiffs failed to quiet title based on a certificate of title. In a second action, the plaintiffs claimed title by adverse possession. (Id., 555 N.E.2d at pp. 230-231.) The court stated: "The gravamen of the plaintiffs' complaint in both lawsuits was the same; the plaintiffs claimed ownership of the disputed land. . . . This was the primary issue in dispute . . . . The plaintiffs were not entitled to pursue their claim of ownership through piecemeal litigation . . . ." (Id. at p. 232.) The court held that the plaintiffs could have and should have asserted the adverse possession claim in the first action, and therefore were barred from litigating their claim in the second action. (Ibid.)