Duncan v. Chartiers Nature Conservancy, Aplt.

Summary

The Supreme Court of Pennsylvania affirmed the lower court’s order directing the Chartiers Nature Conservancy to file an ejectment action, holding that a plaintiff seeking a quiet‑title action under Pa.R.C.P. 1061(b)(1) must show actual possession through dominion and control, and that the record title holder’s presumption of possession can be overcome by such evidence; the court also held that whether the land is unenclosed woodland is irrelevant to this preliminary jurisdictional question.