Response or Comment
In Wissinger v. Reed et al., 125 Pac. lO3O (Aug. 24, 1912) the Supreme Court of Washington held that actual possession of land for the statutory period would confer title upon the occupant, although the possession was under a mistaken belief of ownership. While the doctrine that title to real property may be acquired by adverse possession has been firmly established in English and American law for a great many years, no little difficulty and confusion have arisen in determining what possession is adverse, especially where the actual possession upon which the claim of title is based has been under a mistaken belief that the land so occupied was properly in the possession of the claimant as owner.
Aigler, Ralph W. "Possession under Mistake as Adverse Possession." Mich. L. Rev. 11 (1912): 57-8.