Adverse possession cannot be acquired merely by mowing grass and tending the lawn

Although mowing grass can be a factor in demonstrating “possession” of property, it cannot (by itself) prove exclusion of the record owner or “actual possession” sufficient to obtain title by adverse possession. Hovet v. Dahl, 9 N.W.3d 699 (N.D. 2024). Nor is it sufficient to prove “acquiescence” to a change in the border between the properties.