NC Ents., L.L.C. v. Norfolk & W. Ry. Co.

Summary

The Ohio Supreme Court reversed the Ninth District Court of Appeals, holding that lawn‑maintenance activities alone are not open and notorious enough to satisfy the adverse‑possession element, that the statute of limitations cannot begin without a legally sufficient use, and that lawn‑maintenance is only relevant when a structure or change has existed for the full 21‑year period.