Ls-land.issue.19-911.08 Instant

Even if the Torrens bar were absent, IRA’s recreational use fails the “adverse and hostile” requirement. Jurisdictions are split. This Court follows the for unenclosed wildlands (see Goddard v. Milligan , 2005). The Strip, being unfenced and located on a barrier island with only seasonal human traffic, is analogous to a “public recreational passage.” Without evidence of enclosure, cultivation, or explicit warning to the owner, such use is presumed to be licensed by the owner’s silence — not adverse. The removal of Coastal’s 2002 sign strengthens IRA’s conduct as disruptive, but does not retroactively convert 39 prior years of passive recreation into adverse use.