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The standard for continuous possession for adverse possession requires a degree of occupancy and use of the property that the average owner would make of that particular property. There must be no break in the essential attitude of mind required for adverse use. If abandonment without the intent to return occurs, the continuity of an adverse possession is lost.
It has become firmly established that the requisite possession requires such possession and dominion 'as ordinarily marks the conduct of owners in general, in holding, managing, and caring for property of like nature and condition.' Whalen v. Smith, 183 Iowa 949, 953, 167 N.W. 646 (1918). Also see Mesher v. Connolly, 63 Wn.2d 552, 388 P.2d 144 (1964); Skoog v. Seymour, 29 Wn.2d 355, 187 P.2d 304 (1947); Butler v. Anderson, 71 Wn.2d 60, 64, 426 P.2d 467 (1967); Fadden v. Purvis, 77 W.D.2d 22, 459 P.2d 385 (1969).
In F. Clark, Law of Surveying and Boundaries, § 561 (3d ed. 1959) at 565: 'Continuity of possession may be established although the land is used regularly for only a certain period each year.' Further, at page 566: This rule [which permits tacking] is one of ...
