The Affect of a Deed Conveying After-Acquired Title on a Claim Under the Texas Five-Year Adverse Possession Statute
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Examines the Texas Court of Civil Appeals at Tyler’s case Daniels v. Jones. The court in Daniels held that a claimant could rely on a deed conveying after-acquired title for the purposes of establishing an adverse possession claim. The author comments that, although the precedent in Daniels should be followed, the court erroneously identified Daniels as a question of first impression, when it had decided the opposite holding in Davis v. Morley in 1943.