In Anderson v. Hudak, 80 Wn. App. 398, 907 P.2d 305 (Wash. Ct. App. 1995), the Washington Court of Appeals stated that "evidentiary difficulties arise in proving that one own er 'possesses' or 'uses' a line of trees to the exclusion of another."
The court further explained that usage of trees that would support a claim of adverse possession "included acts such as clearing land, mowing grass and maintaining shrubs and plants." Id.
The court noted, however, that the "planting of trees alone, without some use that is open and hostile, does not satisfy the elements of adverse possession." Id. at 404.