## Facts

- The Sanderses owned and operated Shady Glen Trailer Park on a parcel in Snohomish County; the Chaplins owned the adjacent undeveloped parcel to the east.
- The disputed property was a strip along the western edge of the Chaplins’ record title, adjacent to the Sanderses’ boundary.
- In 1957–1958, the Sanderses’ predecessors cleared land for the trailer park, treated a drainage ditch as the practical boundary, and constructed and used a road on the strip for ingress and egress.
- In 1960, the eastern owner obtained a survey identifying the true boundary and notified the trailer-park owners that the road encroached on the eastern parcel.
- Despite notice, successive trailer-park owners continued to use and maintain the road and the area between the road and ditch as part of the park (including mowing and landscaping).
- In 1976, the Sanderses bought the trailer-park parcel with actual notice of the true boundary and continued the same uses.
- In 1978, the Chaplins purchased the eastern parcel; after learning of the encroachment by survey, they sued to quiet title.
- The trial court found adverse possession as to the road but not the entire strip; the Court of Appeals reversed for lack of hostility.

## Issues

1. Whether a claimant’s actual knowledge of another’s record title defeats the “hostility” element of adverse possession.
2. Whether the record owner’s actual knowledge of the claimant’s use satisfies the “open and notorious” element.

## Decision

- The Washington Supreme Court reversed the Court of Appeals and reinstated judgment for the Sanderses.
- The court held hostility is determined objectively and is not negated by the possessor’s subjective belief or actual notice of the true owner’s title.
- The court held open-and-notorious possession is satisfied when the true owner has actual knowledge of the adverse use throughout the statutory period.
- Title was quieted in the Sanderses for the entire disputed strip used as part of the trailer park, based on tacking of successive possessors and proof of actual, open and notorious, exclusive, continuous, and hostile possession for the statutory period.

## Legal Principles

- Hostility in adverse possession is an objective inquiry: the claimant must treat the land as their own against the world for the statutory period.
- The claimant’s subjective intent (good faith mistake or knowing encroachment) and actual notice of another’s record title do not defeat hostility if the claimant continues to possess under a claim of right.
- Open-and-notorious possession is satisfied by possession that would put a reasonable owner on notice; it is also satisfied where the record owner in fact has actual knowledge of the adverse use throughout the statutory period.
- Successive adverse possessors in privity may tack periods of possession to meet the statutory period.

## Conclusion

The court clarified Washington adverse possession doctrine by adopting an objective standard for hostility and by recognizing that a record owner’s actual knowledge of the adverse use satisfies open-and-notorious possession, resulting in title being quieted in the long-term trailer-park operators for the entire disputed strip.


Chaplin v. Sanders, 100 Wn.2d 853, 676 P.2d 431 (Wash. 1984)