Cahill v. Morrow Rhode Island Supreme Court, 2011. Facts: P is the sole owner of lot 20, having inherited it after her mother passed away in 1975 and she purchased her siblings' shares in 1977. D, and his heirs, own(s) the adjacent lot, lot 19, and owns in partnership with his brothers the next lot over 18, both purchased in 1969. D never made any improvements on lot 19, instead it remains a field between lots 20 and 18. Between 1971 and 1975, P occasionally cut the grass of lot 19 and placed furniture and planted flowers on it. After 1975, when P began to live in lot 20 permanently, she continued to occasionally cut lot 19’s grass, and would arrange various pieces of lawn furniture and flags, and hung a clothesline over the lot. Beginning in 1987, she hosted an annual family gathering, during which she and her guests made use of lot 19 as a venue for the party. P would also occasionally host other friends on lot 19. She hosted other festivals on lot 19 from 1991 on. In 1997, P wrote to D inquiring about purchasing lot 19. P again inquired in 2002, neither inquiry received a response from D. D passed away in 2002. P retained counsel in 2005 and sent a letter to D in 2006 claiming adverse possession of a “20-foot” strip of the land on lot 19. After a survey of the land, P filed suit for a declaration that she was the owner of lot 19 based on adverse possession. Procedural History: Trial court finds for P, D appeals. Issue: Can incidents of ownership by a party claiming adverse possession be considered if they occurred after the party made an offer to purchase the property from the owner outside of the context of ending a pending dispute over ownership? Holding: No, the trial court erred in considering any incident of ownership post-1997. This case is distinguishable from Tavares because P’s offer to purchase the property objectively declared the superiority of D’s title and was not made in an attempt to make peace in an ongoing dispute over title. Judgment is reversed and remanded for the judge to consider (1) whether P s objective manifestation of D’s superior title affects her hostile possession over lot 19 during the statutory period, and (2) whether P’s actions pre-1997 alone are enough to constitute enough evidence to support adverse possession.