Carpenter v. Ruperto
315 N.W.2d 782 (1982)
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Rule of Law:
To acquire title by adverse possession under a claim of right, the possessor must act in good faith, which is not established if the possessor knows they have no title to the property and no basis for claiming an interest in it.
Facts:
- In 1951, Virginia Carpenter and her husband purchased and moved into a home on Lot 144 in Des Moines.
- The adjacent lot to the north, part of Lot 62, was an undeveloped cornfield owned by others.
- Carpenter knew that her property's dimensions did not include the cornfield and that someone else held title to it.
- In 1952, Carpenter and her husband cleared a 60-foot strip of the adjacent lot, graded it, and planted grass to extend their yard.
- Over the next three decades, Carpenter treated the disputed strip as her own, planting bushes, installing a propane tank in 1964, and building a driveway that encroached five feet onto it in 1975.
- During the 1960s, Carpenter examined the plat of the adjacent lot at the courthouse.
- The record title holders of Lot 62, including the Rosenfelds (1960-1978) and later the defendants, paid all property taxes and special assessments on the entire lot, including the disputed strip.
- At one point, Carpenter obtained permission from the Rosenfelds to keep a horse on their lot.
Procedural Posture:
- Virginia Carpenter (plaintiff) filed an action in an Iowa trial court (in equity) to quiet title to a parcel of land, suing Charles L. Ruperto, Edith C. Ruperto, and Tom McCormick (defendants).
- The trial court held that Carpenter failed to establish her claim of adverse possession because her possession was not under a good faith claim of right.
- The trial court, on equitable grounds, ordered the defendants to deed a small portion of the land (for a driveway) to Carpenter and to pay costs for moving her propane tank.
- Carpenter, as appellant, appealed the trial court's adverse possession ruling to the Supreme Court of Iowa.
- The defendants, as cross-appellants, cross-appealed the portion of the trial court's decree granting equitable relief to Carpenter.
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Issue:
Does a person who knowingly possesses and improves land to which they have no title, and no basis for claiming an interest, satisfy the 'claim of right' element required for adverse possession?
Opinions:
Majority - McCormick, J.
No. A person who knowingly possesses land without any title or basis for claiming an interest does not satisfy the 'claim of right' element for adverse possession because it lacks the essential component of good faith. The court affirmed that while a 'claim of right' does not require a perfect title, it does require a good faith belief in one's right to the property. The doctrine of adverse possession presupposes a defective title, not a complete absence of any claim coupled with knowledge of another's ownership. Carpenter knew the disputed land was not hers and she had no interest in it or claim to it; her possession was not based on a mistake, confusion, or a defective instrument. To allow a mere possessor who knows they have no rights to the property to acquire title would be to recognize 'squatter’s rights' and put a premium on dishonesty, which contradicts the purpose of the doctrine. Therefore, Carpenter failed to prove a good faith claim of right.
Analysis:
This decision solidifies the good faith requirement as a crucial component of the 'claim of right' element for adverse possession in Iowa. It clarifies that a claimant's subjective knowledge is determinative; a person cannot be a knowing trespasser from the outset and later satisfy the claim of right element. This holding distinguishes between possessors acting under a mistake of fact or a defective title (who may succeed) and knowing squatters (who will fail). The case serves as a key precedent to prevent the doctrine of adverse possession from being used to reward intentional land appropriation, thereby reinforcing the rights of titleholders against those who knowingly encroach on their land.
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