## Facts

- Christy was in possession of a tract of land.
- After the United States acquired the region from Mexico, Scott forcibly removed Christy from the land and kept him out of possession.
- Christy sued Scott in a land-possession action, alleging that Christy held title and that Scott’s forcible ejectment was unlawful.
- Scott did not prove that he held legal title to the property.
- Instead, Scott raised a substantive defense aimed at Christy’s claim of title: even if Christy once had title, it was not valid because the State of Texas held the true legal title.
- Scott did not claim to act for Texas, hold under Texas, or have any other connection to Texas’s asserted ownership.
- Christy demurred to Scott’s defense, arguing that a mere intruder could not defeat Christy’s claim by relying on an outstanding title in a third party.
- The trial court ruled for Scott, and Christy sought review in the United States Supreme Court.

## Issues

1. Whether a defendant who shows no title in himself may defeat a dispossessed prior possessor’s claim to recover land by proving an outstanding title in the State of Texas, when the defendant is not connected to that title.

## Decision

- The Supreme Court reversed the judgment for Scott and remanded.
- The Court treated Scott as a wrongdoer who did not justify his possession by proving any right or title in himself.
- As against a forcible intruder, Christy could recover based on prior possession unless Scott showed a better right to possession.
- Scott could not defeat Christy merely by asserting that Texas held superior title, because Scott did not connect his entry or possession to Texas’s asserted ownership.

## Legal Principles

- Prior peaceable possession is sufficient to maintain an action to recover land against a mere wrongdoer who enters without right.
- A defendant who cannot show title or a superior right to possession generally may not rely on an outstanding title in a stranger (including the State) unless the defendant connects himself to that title.
- In a possessory dispute against an intruder, the plaintiff need not prove perfect title against the world; it is enough to show a better right to possession than the defendant.

## Conclusion

Christy v. Scott holds that a defendant who forcibly ousts a possessor and cannot show title or authority for his entry cannot avoid liability by pointing to an alleged superior title in the State of Texas. Because Scott was not connected to Texas’s claimed ownership and offered no independent right to possess the land, Christy’s prior possession was sufficient to require reversal and a remand for further proceedings.


Christy v. Scott, 55 U.S. 282 (1852)