Amador v. Berrospe
In Amador v. Berrospe, 961 S.W.2d 205 (Tex. App.--Houston 1st Dist. 1996, writ denied), a party claimed adverse possession against his cotenant.
The Court held that to do so, the claimant must prove the additional element of "repudiation of title or ouster by the cotenant" claimant. Id. at 208.
In Amador, the claimant "maintained, insured, and paid taxes on the property for fourteen years" after the event that created the co-tenancy occurred, just as he had done prior to that event. Id. at 209.
However, since his actions post-occurrence were in conformity with his actions pre-occurrence, those actions could not have put his cotenant on notice of an adverse claim. Id.
Thus, the Court found the adverse possession claim to be without merit as a matter of law.