Grace v. Koch

In this case, we examine the common-law doctrine of adverse possession. For the reasons that follow, we hold that adverse possession must be proven by clear and convincing evidence and affirm the court of appeals’ determination that the Kochs had not established title by adverse possession.

To acquire title by adverse possession, the party claiming title must show exclusive possession and open, notorious, continuous, and adverse use for a period of twenty-one years. Pennsylvania Rd. Co. v. Donovan (1924), 111 Ohio St. 341, 349-350, 145 N.E. 479, 482. See, also, State ex rel. A.A.A. Invest. v.…