Board of Trustees of Tecolote Land Grant v. Griego

OPINION

KENNEDY, Judge.

{1} Two days after the district court entered its final order in this case, our Supreme Court decided In re Estate of Duran, 2003-NMSC-008, 133 N.M. 553, 66 P.3d 326 (hereinafter Duran). In Duran, the Court clarified the legal requirements for a tenant in common to establish individual title to common land by adverse possession. Those requirements are stringent and robust. In this case, we have the advantage of being able to add Duran to the existing precedent in a way that clarifies the problem faced below. Determining that the district court’s decision in this matter…