Anthony v. Searle

In Anthony v. Searle, 681 A.2d 892 (R.I. 1996), the Rhode Island Supreme Court wrote that "cultivating land, planting trees, and making other improvements in such a manner as is usual for comparable land have been successfully relied on as proof of the required possession." 681 A.2d 892 at 898. Anthony thus suggests that our Supreme Court, like the courts of other jurisdictions, would require proof of maintenance or usage of the trees or an area around them in addition to their mere planting, for the requisite statutory period, to establish adverse possession based on a tree line.