## Facts

- The dispute concerned the common boundary between neighboring properties in Manoa Valley, Oahu, and a 2,016-square-foot strip identified as parcel 15, lying between Campbell’s parcel 4 (east) and Hipawai’s parcel 14 (west).
- Campbell asserted paper title to parcel 15 through an 1853 royal patent chain.
- Hipawai (and its predecessor in interest) claimed parcel 15 through conveyances and adverse possession, supported by evidence that parcel 15 had long been treated and used as part of parcel 14.
- Witnesses testified that parcel 15 was cultivated with parcel 14 as early as 1918 and continued to be farmed and used by successive occupants for decades.
- Campbell’s predecessor on parcel 4 began living there around 1936 and did not object to the neighboring cultivation and use of parcel 15 for many years.
- A later owner (Chun) acquired parcels 14 and 15 in 1957, placed a second house near the asserted boundary, and continued using parcel 15 as part of his property; he conveyed the property to Hipawai in 1968.
- In 1977, Campbell cleared the area and rebuilt a fence on the disputed strip; the fence was removed, and Campbell filed a quiet title action.

## Issues

1. Whether the trial court erred by instructing the jury that adverse possession required a 20-year limitations period rather than a 10-year period under applicable Hawaii law.
2. Whether the instructional error warranted reversal where the evidence could support a finding that Hipawai (or its predecessors) acquired title to parcel 15 by adverse possession.

## Decision

- The Intermediate Court of Appeals held the jury was erroneously instructed on the limitations period governing Hipawai’s adverse possession claim.
- The court concluded the applicable period was 10 years, not 20 years, under the governing statute-of-limitations framework.
- Because the jury could have found adverse possession under a correct instruction, the judgment quieting title in Campbell was reversed.
- The case was remanded for further proceedings consistent with the correct limitations period.

## Legal Principles

- Adverse possession claims must be evaluated under the correct statutory limitations period; a misstatement of that period in jury instructions is reversible error when it may affect the verdict.
- Under the applicable Hawaii limitations framework addressed by the court, a 10-year period governed the adverse possession claim at issue rather than a 20-year period.
- Where evidence could support a finding of adverse possession, an erroneous instruction that increases the required period of possession can materially prejudice the claimant and require a new determination under the proper legal standard.

## Conclusion

The court reversed a quiet-title judgment for the record owner because the jury was instructed to apply a 20-year adverse possession period instead of the applicable 10-year period, and remanded for further proceedings under the correct standard.


Campbell v. Hipawai Corp., 639 P.2d 1119 (Haw. Ct. App. 1982)