California, United States of America
The following excerpt is from Huang v. Wells Fargo Bank, N.A., 261 Cal.Rptr.3d 798, 48 Cal.App.5th 431 (Cal. App. 2020):
"[Q]uiet title actions have special rules for when the limitations period begins to run." ( Salazar v. Thomas (2015) 236 Cal.App.4th 467, 477, 186 Cal.Rptr.3d 689 ( Salazar ).) " "[A]s a general rule, the statute of limitations [for a quiet title action] does not run against one in possession of land." [Citation.] 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." ( Ibid. ) Even when a party in possession knows there is a potential adverse claim, "there is no reason to put him to the expense and inconvenience of litigation until such a claim is pressed against him." ( Muktarian , supra , 63 Cal.2d at pp. 560561, 47 Cal.Rptr. 483, 407 P.2d 659.) "Thus, mere notice of an adverse claim is not enough to commence the owners statute of limitations." ( Salazar , at p. 478, 186 Cal.Rptr.3d 689.)
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