Dale v. Stringer
In Dale v. Stringer, 570 S.W.2d 414 (Tex. App.--Texarkana 1978, writ ref'd n.r.e.), the adverse claimant, Stringer, had possessed the property only nine years and could not ripen the adverse title by her own possession. She then relied on the possession of a predecessor in title who had adversely possessed the property from the 1930s to the 1950s. Id. at 417.
The court found that a limitation title had matured in the predecessor. When title by limitation has matured, there is no further place for tacking, and the title so matured cannot be transferred orally, but can be conveyed only by an instrument in writing. Id. at 418.
The instrument must include the disputed tract in order to convey the matured title. Id.