California, United States of America
The following excerpt is from Salazar v. Thomas, F067831, F068618 (Cal. App. 2015):
First, "'as a general rule, the statute of limitations [for a quiet title action] does not run against one in possession of land.'" (Tannhauser v. Adams (1947) 31 Cal.2d 169, 175.) Part of the rationale for this special rule for quiet title actions is an unwillingness to convert a statute of limitations into a statute that works a forfeiture of property rights on the person holding the most obvious and important property rightnamely, possession. (Id. at p. 175.)
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