In Century Insurance Co. Ltd. v. Guerrero, 2009 MP 16, 8 N. Mar. I. 292, the Court had to determine whether the six or twenty year period governed a suit concerning an agreement to lease. Id. § 7.
It held that such agreements were more similar to contract actions than actions seeking the recovery of land, and that the statute of limitations applicable to contracts, a six year period, also governed most actions on a lease. Id. § 29.
In Century the Court stated that "an action seeking the recovery of real property does not automatically trigger the longer statute of limitations period applicable to actions for the recovery of land when the claim actually concerns a different theory." Id. § 16.
In support of this proposition, Century cited to Brown v. Ramsey, 472 S.W.2d 322, 323-24 (Tex. App. 1971), for the proposition that when a suit seeks to recover land by overturning a judgment, the statute of limitations period governing the recovery of land is not applicable, but instead the period for challenging judgments controls. Id. § 19.