The defendant appealed from the judgment of the trial court to the Appellate Court, and we transferred the appeal to this court pursuant to General Statutes § 51-199 (c) and Practice Book § 65-1.

John J. O’Connor was also a plaintiff, but he withdrew from the action and is not a party to this appeal. The trial court found that the named plaintiff, Theresa P. O’Connor, had acquired John J. O’Connor’s interest in the property at issue and, therefore, rendered judgment in favor of Theresa P. O’Connor only. In the interest of simplicity, we refer to Theresa P. O’Con-nor as the plaintiff throughout this opinion.

See Black’s Law Dictionary (9th Ed. 2009) p. 1603 (defining “cotenancy” as “[a] tenancy with two or more coowners who have unity of possession” and giving as examples “a joint tenancy and tenancy in common”); see also, e.g., White v. Beckwith, 62 Conn. 79, 80, 25 A. 400 (1892).

The defendant also claims that the trial court improperly (1) disregarded its own memorandum of decision on the defendant’s motion for summary judgment with respect to her claim seeking equitable relief in reaching a decision on her first claim, and (2) took judicial notice of evidence from prior civil actions involving the parties. Because we conclude that the trial court improperly found that the plaintiff had overcome the presumption against adverse possession by a cotenant, despite its action in taking judicial notice, we need not address those claims.

See General Statutes (Cum. Sup. 1967) § 46-12 (intestate distribution of one-third interest to surviving spouse); General Statutes (Rev. to 1958) § 45-274 (intestate distribution of residue to children).

To the extent the dissent refers to the fact that the defendant prevailed in the prior litigation to bolster its contention that the trial court properly ruled in favor of the plaintiff in this case; see footnote 2 of the dissenting opinion; its reliance is misplaced for at least four reasons. First, the trial court expressly declined to consider the outcome in the prior litigation when it granted the defendant’s motion for summary judgment on the second count of the plaintiffs complaint seeking equitable relief. Second, the trial court explained in its memorandum of decision that it had considered the prior litigation only as evidence of the parties’ acrimonious relationship and notice, a point that the plaintiff expressly conceded in her brief to this court. Moreover, the court could not have done otherwise in light of its observation, in granting the summary judgment motion, that the outcome in the prior litigation involving mirror image allegations did not mean that the plaintiff was “entitled to prevail on [her] reciprocal claims in the present case as a matter of “ ‘fairness,’ without having to meet the rigors of proving adverse possession.” Third, the trial court in the prior litigation did not address the effect of the parties’ relationship as cotenants in its adverse possession analysis, and, therefore, the outcome in that litigation is irrelevant in the present context, in which the cotenant relationship has been placed directly in issue. Fourth, because the plaintiff did not appeal from the judgment in the prior litigation, in which she was the losing party, it has no precedential value. Accordingly, insofar as the dissent indirectly relies on the outcome in the prior adverse possession litigation in support of its analysis, such reliance is improper.

*568The dissent also claims that “the pleadings offered and the positions taken by the present defendant in [the prior litigation] are highly relevant [to this case]”; footnote 2 of the dissenting opinion; because the trial court, in granting the defendant’s motion for summary judgment on the plaintiff’s equitable claim, stated that “certain aspects of the previous litigation among the parties may have a bearing on the resolution of the present [action], such as by way of collateral estoppel, judicial admissions or evidentiary admissions . . . We first note that the plaintiff has made no such claim. Second, the trial court made no reference to the effect of the prior litigation by way of collateral estoppel, judicial admissions or evidentiary admissions on its resolution of the claim in the present action. The court merely explained that the history of acrimonious litigation between the parties was strong evidence from which it could conclude that the plaintiff had given notice to the defendant that she was claiming an exclusive right to the property. The court neither stated nor implied that it had relied on the pleadings and the parties’ positions in the prior litigation in reaching its conclusion, even when the defendant asked the court in her motion for articulation to explain how it had utilized the record in the prior litigation when deciding the present action. Accordingly, the dissent’s claim that the trial court relied on the pleadings and the parties’ positions in the prior litigation to resolve the plaintiffs adverse possession claim has no basis in the record and is, at best, highly speculative.

Furthermore, in citing the defendant’s allegations and claims in the prior litigation to discredit her claim in the present case that the plaintiff did not give notice of her intent to occupy the property exclusively, the dissent fails to consider our law on judicial notice. According to an authoritative treatise on Connecticut evidence, “[c]ourt records may be judicially noticed for their existence, content and legal effect. . . .

“Care should be taken [however] to avoid noticing judicial records in one case as evidence upon which to find facts in another case. For example, one can judicially notice that certain testimony was given in a case, but not that it was true.

“Similarly, a judgment in one case cannot be used to establish facts in another case without complying with the hearsay rule.” (Citations omitted.) C. Tait & E. Prescott, Connecticut Evidence (4th Ed. 2008) § 2.3.4 (d), p. 97.

Thus, when a court takes judicial notice of a prior case, it is not all inclusive but is directed to specific records that must be carefully construed in the subsequent litigation. In the present case, the trial court did not take judicial notice of the defendant’s allegations and claims in the prior litigation but of the general fact that the parties had been involved in two previous lawsuits. Moreover, although the dissent relies on the allegations in one of those actions to support its conclusion that the defendant had contended that she gave notice to the plaintiff of her exclusive possession of another property in exactly the same manner that the plaintiff contends that she gave notice to the defendant in this action, the trial court made no determination regarding notice in the prior action and did not apply the legal standard employed when the parties are tenants in common. We thus regard the dissent’s reliance on the defendant’s allegations and claims in the prior action as a distraction that has no relevance in the present case.

The plaintiff entered exhibits at trial establishing that taxes on the property between 1987 and 2007 were: 1987, $403.28; 1988, $419.74; 1990, $436.20; 1991, $465.82; 1992, $498.74; 1993, $510.26; 1994, $510.26; 1995, $17.05; 1996, $17.34; 1997, $17.75; 1998, $18.27; 1999, $18.88; 2000, $19.65; 2001, $20.46; 2002, $21.27; 2003, $27.53; 2004, $28.85; 2005, $20.45; 2006, $21.22; 2007, $21.78.

In its articulation, the trial court stated that the plaintiff had prepared a quitclaim deed immediately prior to the litigation “in an effort to reach a settlement of the property issues between the parties.” Thus, the quitclaim deed to which the plaintiffs attorney referred was not the quitclaim deed that the plaintiff had asked the defendant to sign in 1987.

In its memorandum of decision, the trial court noted by way of background that, although the parties were sisters, there was “nothing sisterly about their relationship.” The court further explained: “They have been involved in at least two previous lawsuits before this court. In Larocque v. *572Percoski, [Superior Court, judicial district of Tolland, Docket No. CV-97-0063927-S (February 18, 2003)], Larocque sued O’Connor both as the executrix of their mother’s estate and individually, seeking to quiet title to two parcels of land .... Interestingly enough, in that case, Larocque prevailed, successfully proving her title to [those two lots] by adverse possession under a factually similar scenario.

“The second litigation involved a [law]suit brought by Larocque against O’Connor, claiming that O’Connor unduly influenced their mother to disinherit her (Larocque). This court, after [a] trial, [rendered] judgment for O’Connor finding no undue influence. That decision was appealed to the Appellate Court, which affirmed the judgment. Larocque v. O’Connor, 90 Conn. App. 156 [167, 876 A.2d 1229] (2005).”

Many of our sister states also apply this standard. See, e.g., Lines v. State, 245 Ga. 390, 396, 264 S.E.2d 891 (1980); Davis v. Mayberry, 241 P.3d 663, 667 (Okla. App. 2010); Peeples v. Bellingham,, 93 Wn. 2d 766, 771, 613 P.2d 1128 (1980); Perpignani v. Vonasek, 129 Wis. 2d 478, 490, 386 N.W.2d 59 (App. 1986), rev'd in part on other grounds, 139 Wis. 2d 695, 408 N.W.2d 1 (1987).

The dissent claims that it is not clear whether “the majority considers the conclusion that a particular element of adverse possession such as notice or intent is satisfied in a given case to be a factual finding, subject to deferential appellate review, or, [alternatively], alegal conclusion, subject to de novo review.” Footnote 3 of the dissenting opinion. The dissent states that, in its view, reversal is warranted, “even under a deferential standard of review,” only if “(1) there is no evidence to support the trial court’s factual findings; (2) the evidence is so slight that no reasonable fact finder could find the elements of adverse possession satisfied by clear and convincing evidence; or (3) the [trial court’s] factual findings fail to satisfy the established legal standards for adverse possession.” Id.

We disagree that this opinion is unclear. As we stated in Caminis, a factual finding in an adverse possession case will be deemed by a reviewing court to be clearly erroneous, and thus insufficient as a matter of law, when there is either no evidence in the record to support it or when there is insufficient evidence to support it and “the reviewing court on the entire evidence is left with the definite and firm conviction that a mistake has been committed . . . .” Caminis v. Troy, supra, 300 Conn. 306. Accordingly, it would seem that the principal difference between our view and that of the dissent is that the dissent would defer to the trial court’s conclusions on the elements of adverse possession even when the court’s factual findings are supported by evidence that a reviewing court would consider insufficient under Caminis.

To the extent we may have characterized findings of adverse possession in some of our prior cases as questions of fact, we also recognized that such findings must be legally consistent with the facts found. See, e.g., Wildwood, Associates, Ltd. v. Esposito, supra, 211 Conn. 43 (“[ajdverse possession is a question of fact, and when found by the trial court will not be reviewed by this court as a conclusion from evidential facts, unless it appears that these facts, or some of them, are legally or logically necessarily inconsistent with that conclusion” [emphasis added; internal quotation marlrs omitted]); Wadsworth Realty Co. v. Sundberg, 165 Conn. 457, 461, 338 A.2d 470 (1973) (“[t]he conclusions which the court reached must stand unless they are legally or logically inconsistent with the facts found or unless they involve the application of some erroneous rule of law material to the case” [emphasis added]). As we explained in Davis v. Margolis, 107 Conn. 417, 140 A. 823 (1928), a conclusion or inference that results from applying a legal standard to the facts found “is often called one of fact; [but] strictly speaking it is one of law and fact, involving, first, the ascertainment of the standard, and then its application to the case in hand.” Id., 420-21. The accepted rule is that, when the factual findings are settled, “[a] judgment rendered [on] facts found will not be reversed or set aside unless some erroneous rule of law material to the case has been applied, or unless a conclusion has been reached, or an inference drawn, from a fact, many facts, or the facts found, which affects the judgment rendered in material degree and is legally or logically inconsistent with that or those facts, or is so illogical or unsound, or so violative of the plain rules of reason, as to be unwarranted in law.” Id., 422; see also Winsted Hosiery Co. v. New Britain Knitting Co., 69 Conn. 565, 575, 38 A. 310 (1897) (“[t]he judgment or ultimate *577conclusion of a court [on] the special facts in issue, as ascertained from the evidence and settled by the trier, is a conclusion of law, and as such reviewable by this court; and this is true whether such facts are settled by a special verdict of a jury or a special finding of a judge”).

Thus, because the dissent repeatedly characterizes the trial court’s findings of fact in adverse possession cases as subject to deferential review without acknowledging the reviewing court’s role in determining whether such findings are legally insufficient, either because they are inconsistent with an established rule of law or because they are supported by a complete lack of evidence or by insufficient evidence, its analysis is seriously flawed.

The dissent claims that the majority improperly relies on Bristol “for the proposition that plenary review of the trial court’s factual conclusions is warranted in the present case” because the standard of review articulated in Bristol, namely, that a “ ‘trial court’s conclusions must stand unless they are legally or logically inconsistent with the facts found or unless they involve the application of some erroneous rule of law material to the case,’ ” is highly deferential. Footnote 6 of the dissenting opinion. The dissent misunderstands our citation to Bristol. As we previously discussed, adverse possession is a mixed question of law and fact. We thus cite Bristol for the proposition that the trial court’s legal conclusions regarding adverse possession are subject to plenary review. To the extent that the dissent also claims that the foregoing language from Bristol is by its very nature deferential, we note that reviewing courts have used similar language countless times in describing the plenary standard of review. See, e.g., Fisher v. Big Y Foods, Inc., 298 Conn. 414, 423-24, 3 A.3d 919 (2010) (“[w]hen ... the trial court draws conclusions of law, our review is plenary and we must decide whether its conclusions are legally and logically correct and find support in the facts that appear in the record” [internal quotation marks omitted]); Crews v. Crews, 295 Conn. 153, 161, 989 A.2d 1060 (2010) (“[W]hen an appellant’s claim alleges that the facts found by the court were insufficient to support its legal conclusions, we are presented with a mixed question of fact and law to which the plenary standard of review applies. . . . Our task is to determine whether the court’s conclusions are legally and logically correct and find support in the facts that appear in the record.” [Internal quotation marks omitted.]); PJM & Associates, LC v. Bridgeport, 292 Conn. 125, 133, 971 A.2d 24 (2009) (“[w]hen . . . the trial court draws conclusions of law, our review is plenary and we must decide whether its conclusions are legally and logically correct and find support in the facts that appear in the record” [internal quotation marks omitted]); Gateway Co. v. DiNoia, 232 Conn. 223, 229, 654 A.2d 342 (1995) (“[w]hen . . . the trial court draws conclusions of law, our review is plenary and we must decide whether its conclusions *578are legally and logically correct and find support in the facts that appear in the record” [internal quotation marks omitted]); Altray Co. v. Groppo, 224 Conn. 426, 431, 619 A.2d 443 (1993) (“[o]ur review of [the] claims is plenary . . . and we will reverse the trial court if its conclusions are legally or logically incorrect or find no support in the facts that appear in the record” [citation omitted]); Morton Buildings, Inc. v. Bannon, 222 Conn. 49, 53, 607 A.2d 424 (1992) (“[w]hen . . . the trial court draws conclusions of law, our review is plenary and we must decide whether its conclusions are legally and logically correct and find support in the facts that appear in the record”); Auto Glass Express, Inc. v. Hanover Ins. Co., 98 Conn. App. 784, 792, 912 A.2d 513 (2006) (“[b]eeause the resolution of [the] claim involves a question of whether the facts found were insufficient to support the court’s legal conclusion, this issue presents a mixed question of law and fact to which we apply plenary review”), cert, denied, 281 Conn. 914, 916 A.2d 55 (2007); Winchester v. McCue, 91 Conn. App. 721, 726, 882 A.2d 143 (“[a]s the plaintiff asserts that the facts found were insufficient to support the court’s legal conclusion, this issue presents a mixed question of law and fact to which we apply plenary review”), cert. denied, 276 Conn. 922, 888 A.2d 91 (2005).

Although the scheme of adverse possession in Connecticut, like that of all other states, is based on a statute of repose for actions against an adverse possessor, the mere existence of such statutes does not compel the existence of adverse possession in the form that we know today. To the contrary, “[b]y their terms, most statutes of limitation [including Connecticut’s] merely terminate the record owner’s access to judicial assistance in recovering possession of his land. The doctrine of adverse possession takes these statutes one conceptual step further by providing that the adverse possessor . . . actually gains legal title, displacing the record owner .... This result does not flow ineluctably from the language of the statutes.” J. Stake, “The Uneasy Case for Adverse Possession,” 89 Geo. L.J. 2419, 2421-22 (2001).

General Statutes § 52-575 (a) provides: “No person shall make entry into any lands or tenements but within fifteen years next after his right or title to the same first descends or accrues or within fifteen years next after such person or persons have been ousted from possession of such land or tenements; and every person, not entering as aforesaid, and his heirs, shall be utterly disabled to make such entry afterwards; and no such entry shall be sufficient, unless within such fifteen-year period, any person or persons claiming ownership of such lands and tenements and the right of entry and possession thereof against any person or persons who are in actual *579possession of such lands or tenements, gives notice in writing to the person or persons in possession of the land or tenements of the intention of the person giving the notice to dispute the right of possession of the person or persons to whom such notice is given and to prevent the other party or parties from acquiring such right, and the notice being served and recorded as provided in sections 47-39 and 47-40 shall be deemed an interruption of the use and possession and shall prevent the acquiring of a right thereto by the continuance of the use and possession for any length of time thereafter, provided an action is commenced thereupon within one year next after the recording of such notice. The limitation herein prescribed shall not begin to run against the right of entry of any owner of a remainder or reversionary interest in real estate, which is in the adverse possession of another, until the expiration of the particular estate preceding such remainder or reversion-ary estate.”

See An Act for Limitation of Actions, and for Avoiding of Suits in Law, 21 Jac. I, c. 16 (1623-24). That statute provided in relevant part: “For quieting of Mens Estates and avoiding of Suits .... That all Writts of Formedon in Descender, Formedon in Remainder and Formedon in Reverter, at any tyme hereafter to be sued or brought of or for any Mannors Lands Tenements or Hereditaments whereunto any pson or psons now hath or have any Title, or cause to have or pursue any such Writt, shall be sued and taken within Twentie yeares next after the end of this . . . Session of Parliament; and after the said Twentie yeares expired, no pson or psons, or any of their heires, shall have or mayntayne any such Writt of or for any of the said Mannors Lands Tenements or Hereditaments; and that all Writts of Formedon in Descender Formedon in Remaynder and Formedon in Reverter of any Mannors Lands Tenements or other Hereditaments whatsoevr, at any tyme hereafter to be sued or brought by occasion or meanes of any Title or cause hereafter happening, shalbe sued and taken within Twentie yeares next after the Title and Cause of Acción first descended or fallen, and at no tyme after the said Twentie years: And that no pson or psons that now hath any Right or Title of Entry into any Mannors Lands Tenements or Hereditaments nowe held from him or them, shall thereunto enter but within Twenty yeares next after the end of this . . . Session of Parliament, or within twenty yeares next after any other Title of Entrie accrued; and that no pson or psons shall at any tyme hereafter make any Entrie into any Lands Tenements or Hereditaments, but within Twentie yeares next after his or their Right or Title which shall hereafter first descend or accrue to the same; and in default thereof such psons so not entring, and their Heirs, shalbe utterlie excluded and disabled from such Entrie after to be made; Any former Law or Statute to the contrary notwithstanding.”

The dissent states that “the majority . . . appears to believe that there can be adequate notice of a cotenant’s intent to dispossess only when there is either an express notification or something closely akin to it, [but] a thorough review of the cases reveals that there is no such requirement.” Text accompanying footnote 8 of the dissenting opinion. We reject this reading of our opinion. This court has never stated, nor do we suggest, that notice necessarily must be express, or closely akin to express. To the contrary, although the court in Newell observed that actual, or express, notice by way of refusing to allow a cotenant entry on the property in response to a formal demand would furnish clear evidence of ouster, it also stated that notice may be demonstrated by “any acts which show an actual intent to exclude the co-tenant permanently from his rights.” Newell v. Woodruff, supra, 30 Conn. 497. Our case law thus has determined that actual *584notice is not the only, or even the preferred or most often used, method by which one cotenant in possession of the property may convey an intent to dispossess the other, and we have said nothing in this opinion to cast doubt on the continued viability of that principle. We add that, to the extent the dissent distinguishes between the adverse possessor’s “giving notice” and the ousted party’s “havpng] notice”; footnote 8 of the dissenting opinion; it is a distinction without a difference.

We note that, in well over 200 years, approximately nine cases have been decided by this court, which demonstrates the strength of the presumption against adverse possession, and that, of those nine cases, only five have been decided in favor of the claimant.

The dissent relies on Lucas, among other sources, in claiming that “a cotenant is placed on constructive notice when she is aware that the adverse possessor takes common land from the outset under an exclusive claim of right, rather than as an avowed cotenant” and that, “[i]n those situations, the majority rule is that ‘in the case of an entry hostile in its inception much less evidence is needed to establish that the possession is legally adverse to the possessor’s cotenants ....’” Aside from the fact that constructive notice of this kind is irrelevant in the present case, given the plaintiffs concession that she did not know that she was a tenant in common until 1987 and did not notify the defendant of her intent to occupy the lot exclusively until 1997 through the court and her attorneys, we deem Lucas and the quoted law clearly inapplicable in this factual context for another reason. Although the court in Lucas determined that a cotenant’s quitclaim deed purporting to convey full title was tantamount to notice, such that the grantees held the land adversely to the other cotenants; see Lucas v. Crofoot, supra, 95 Conn. 624-25; the dissent well knows that the quitclaim deed to the plaintiff from her mother in the present case did not purport to convey the entire lot but only such interest as her mother held, which was a partial interest described in a certificate of devise or descent from her father’s estate that previously had been recorded in the land records. Moreover, both the plaintiff and the trial court expressly acknowledged that the quitclaim deed did not convey full title to the plaintiff. In contrast, title to the property in Lucas was recorded in the adverse possessor’s name alone. See id., 621-24. In that case, the court observed that one of several predecessors in title who had been a cotenant explicitly stated in deeding his portion of the property to his successor in title that “all of the other [covenants had conveyed [their interests] to him,” and that the deed to the other portion of the property “expressly warranted the title to that portion of the island against the claims of all other persons.” Id., 625. Accordingly, any legal principle or Connecticut case regarding the effect of a quitclaim deed purporting to convey the entire interest in property to the cotenant in possession is inapposite in the present circumstances, and the dissent’s insistence that “Lucas . . . established the broader proposition that taking under color of any quitclaim deed can provide at least some indication of the grantee’s intent to hold the property exclusively” is misplaced. (Emphasis added.) Footnote 14 of the dissenting opinion. Indeed, the court in Lucas expressly rejected this exact argument when it stated: “The defendants urge that the deeds under which the north part of the island was conveyed were quitclaim deeds, and that a quitclaim of all the grantor’s ‘right, title and interest’ is not inconsistent with the existence of an interest in cotenants, and does not deny that interest. This distinction between the effect of a warranty and a quitclaim deed generally, is doubtless valid; but a deed which, though in form a quitclaim, contains in express terms a disclaimer and disavowal of any interest in cotenants or others, is of as much value as a warranty deed could be in giving notice of the adversary character of the entry and possession thereunder.” Lucas v. Crofoot, supra, 624-25.

*587The dissent, while recognizing the distinction between the present case and Lucas, states that “the relevant question [in this case] is whether a conventional quitclaim deed, which is nevertheless believed by all parties to convey full title to the property, provides any evidence to support the trial court’s finding that the plaintiff intended to hold the land exclusively . . . The dissent specifically claims that “[a]t the very least, as we explained in Lucas, holding under color of title of a quitclaim deed places an affirmative duty on cotenants out of possession to make a ‘hostile move in support of their own title The dissent’s framing of the question, however, disregards an essential legal fact of significance in this case, namely, that a certificate of devise or descent (certificate) reflecting the respective interests of various family members in the lot had been recorded on the land records. This court cannot follow an approach that disregards essential legal facts. Although the mother’s deed to the plaintiff resembled a conventional quitclaim deed, it had to be considered in light of the certificate, which preceded the deed on the land records and could have been discovered quite easily. The dissent also misapplies Lucas because that case did not involve a conventional quitclaim deed, but, rather, an unconventional quitclaim deed that expressly conferred full title to the property on the adverse possessor. It is for this reason, and not because the deed was a quitclaim deed in form, that the court in Lucas concluded that the lack of any “hostile move [by the nonpossessing cotenants] in support of their own title” permitted the trial court properly to conclude that the requirements of adverse possession had been satisfied. Lucas v. Crofoot, supra, 95 Conn. 626. Accordingly, the dissent’s analysis is inapplicable in this context because the court in Lucas premised its conclusion on its understanding that the deed was, in effect, a warranty deed. In any event, the dissent’s analysis under Lucas regarding the quitclaim deed and the plaintiffs belief that she intended to hold the lot exclusively from the time she took possession in 1980, and the cases from other jurisdictions concerning conventional quitclaim deeds on which the dissent relies, are irrelevant in the present context because this court must follow Newell in concluding that the plaintiff could not have given notice before 1987, when the parties first learned that they were tenants in common. See footnote 22 of this opinion and accompanying text.

The dissent relies on Doe and Cam/p for the proposition that there is no “minimum time frame” beyond the statutory period that a cotenant is required to occupy the property exclusively, without more, to establish ouster and adverse possession. Text accompanying footnote 27 of the dissenting opinion. We reject this broadly worded principle. Doe is not a Connecticut case, and it involved a tenant in common who had occupied the property for a period of approximately forty years, almost quadruple the time required to establish ouster under the governing English statute. See Doe ex dem. Fishar v. Prosser, supra, 98 Eng. Rep. 1053. Moreover, although the court in Camp relied on Doe with respect to the element of time, it considered the length of time together with the use of the property as a parsonage in finding for the adverse possessor. See Camp v. Camp, supra, 5 Conn. 298, 302. Accordingly, although we agree with the dissent that this court never has established a “minimum time frame beyond the statutory requirement for adverse possession”; text accompanying footnote 27 of the dissenting opinion; we do not agree that Camp necessarily can be construed to mean that a lengthy possession, without more, is sufficient to prove ouster and adverse possession.

We also do not agree with the dissent that such a rule was adopted in Bryan v. Atwater, supra, 5 Day (Conn.) 181. In that case, the court, citing Doe, merely noted in passing that, “if one tenant in common . . . has been in possession a great number of years, without any accounting to his fellow commoners, this is proper evidence . . . from which the jury may infer an adverse possession.” Id., 188. The court did not apply that principle to the facts of that case, in which the property occupied by the adverse possessor consisted of one acre of land together with a house, a bam, a store and other buildings from which he had derived rents and profits. Id., 182-83 (rendition of facts). Moreover, the court’s passing reference to adverse possession for “a great number of years”; id., 188; cannot be regarded in the same category as the holding in Camp, in which we concluded, under the facts of that case, that adverse possession had been proven because the property had been occupied for a lengthy period of time and used as a parsonage. See Camp v. Camp, supra, 5 Conn. 298, 302. We therefore disagree with the dissent’s claim that the majority has conceded that lengthy acquiescence, without more, is an accepted part of Connecticut law on adverse possession, although we remain open to the possibility that, in some future case, we might reach that conclusion under appropriate facts.

Finally, even if this court had adopted the rule articulated in Doe, the rule would not have been applicable to this case because the plaintiff in the present case did not give notice to the defendant until 1997. Thus, to *591the extent her possession may have been adverse from that time forward, it did not meet the statutory requirement, much less the requirement established in Bryan v. Atwater, supra, 5 Day (Conn.) 188, that the possession be maintained for “a great number of years . . .

The parties stipulated that (1) “The plaintiff . . . has an ownership interest in a piece or parcel of land situated in the town of Somers shown and designated as Lot #54 on a map or plan of lots entitled: ‘PROPERTY OF C.A. PERCOSKI WEST SIDE OF FIELD ROAD’ . . . hereinafter referred to as ‘343 Billings Road,’ ” (2) “[t]he plaintiff and her husband acquired an interest in 343 Billings Road from the plaintiffs mother, Doris Percoski, pursuant to a quitclaim deed dated February 27,1980, which was recorded in the land records of the town [of] Somers ... on February 28, 1980,” (3) “Doris Percoski acquired her interest in the property from her late husband, Constanty Percoski, who was the sole owner of the property when he died intestate in 1971,” (4) “[b]y statute, a one-third interest in the subject property passed to Constanty Percoski’s widow, Doris Percoski, at the time of his demise in 1971,” and (5) “[b]y statute, a one-sixth interest in the subject property passed to each of Constanty Percoski’s four children: [the plaintiff, the defendant] Timothy Percoski and Richard Percoski.”

The dissent claims that adverse possession was not an issue in Newell and that the legal principles articulated in that case apply only in the context of an ejectment action because it would be unjust to find a cotenant hable for damages resulting from an alleged ouster without a mens rea requirement, and there is no indication in Newell that the court would have applied the *593same standard in an action seeking to quiet title. See footnote 17 of the dissenting opinion. We disagree for numerous reasons. First, the passage in Newell containing the language on intent immediately follows, and is part of, the court’s discussion of the general legal principles that apply in adverse possession actions involving cotenants. See Newell v. Woodruff, supra, 30 Conn. 497-98. Second, although not authoritative, the syllabus in Newell states, in its very first paragraph, that “[a]n actual intent to exclude the co-tenant from the enjoyment of the property must be shown, and no evidence on this point is so satisfactory as a refusal to admit him to possession, or to account for profits received, on a demand made”; id., 492 (syllabus); thus clearly implying knowledge of the cotenancy by the party in possession. Third, the dissent appears to misunderstand that a party bringing an action for ejectment must allege wrongful dispossession of his property by the other party in much the same manner that a plaintiff seeking to quiet title in an adverse possession action must allege wrongful dispossession of the defendant’s interest in the property. See, e.g., Simmons v. Parizek, 158 Conn. 304, 305, 259 A.2d 642 (1969); see also Potter v. New Haven, 35 Conn. 520, 522 (1869) (there is no right of action in ejectment unless defendant is disseizor when action is brought). Indeed, there is such a close connection between proof of wrongful possession, other than the statutory time frame, in actions of ejectment and actions to quiet title that adverse possession has been raised as a defense in actions of ejectment. See, e.g., Kiley v. Doran, 105 Conn. 218, 225, 134 A. 792 (1926) (defendant raised defense of adverse possession in action of ejectment in which plaintiff claimed that he had been wrongfully dispossessed of property). Fourth, although the court in Newell did not state that the same principle concerning knowledge applies in actions to quiet title, it also did not state that the principle applies only in ejectment actions. Fifth, the rationale for applying the principle in other actions, namely, that cotenants have an equal right to possess the property and, therefore, that the standard for finding notice and intent must be higher in such cases to protect the rights of the cotenants, is more persuasive than the rationale pertaining to damages cited by the dissent. Sixth, in the only case since Newell that appears to have applied this principle, Diamond v. Boynton, supra, 38 Conn. Sup. 619, the Appellate Session of the Superior Court concluded, in an action alleging breach of the covenants contained in certain warranty deeds, that the defendants lacked the requisite intent to possess adversely against the plaintiff because the defendants, who were spouses, admitted that they thought they owned the entire property. The court specifically quoted from Newell that “[ajctual intent implies actual knowledge, and there can be no wrongful dispossession or wrongful exclusion, no adverse intent and adverse holding, [when] one is in the enjoyment of that which he honestly supposes is his, and has no knowledge that any other person has, or claims to have, a right to participate in the possession of it.” (Internal quotation marks omitted.) Id., 619, quoting Newell v. Woodruff, supra, 498. We therefore disagree with the dissent that this principle is inapplicable in the present context.

The dissent further argues that knowledge of the cotenancy is not required because, in four cases subsequent to Newell, this court repeatedly upheld findings of adverse possession among cotenants without such knowledge. *594See footnote 18 of the dissenting opinion. In three of those cases, however, the names of the parties in exclusive possession were the only names listed in the public records as the property owners during the time of possession, and the court in each case determined that that fact was conclusive in resolving the dispute. See Ruick v. Twarkins, supra, 171 Conn. 155, 157-58 (recording of probate decree provided notice of possessor’s intent to dis-seize); Hagopian v. Saad, supra, 124 Conn. 257 (ownership interest was set forth in “article[s] of agreement . . . recorded like a deed of land” [internal quotation marks omitted]); Harrison v. International Silver Co., 78 Conn. 417, 419, 62 A. 342 (1905) (recitation of facts) (possessor and predecessors in title had actual, exclusive, and uninterrupted possession and use of land for more than twenty-six years prior to action under warranty deed and based on claim of title in fee simple). In the fourth case, the court did not decide whether there had been an ouster and ordered a new trial. See Standard Co. v. Young, 90 Conn. 133, 139, 96 A. 932 (1916). Accordingly, the three cases that actually were decided involved special circumstances in which the recording of the possessors’ names in the public records was an essential consideration, and they cannot be compared with Newell, in which the court did not consider whether those circumstances existed.

Even without this compelling distinction, the dissent’s citation to the foregoing cases for the proposition that Connecticut law permits adverse possession among cotenants without knowledge of the cotenancy is unpersuasive. In Ruick, for example, the court concluded that the plaintiff adverse possessor and her husband had purchased the property as tenants in common, that the plaintiffs application for a probate decree declaring her to be sole owner of the property, which commenced the period of exclusive possession, “was clearly for the purpose and with the intent of eliminating [the husband’s] interest in the land”; (internal quotation marks omitted) Ruick v. Twarkins, supra, 171 Conn. 158-59; and that the plaintiffs ouster of her husband “was clearly and unmistakably demonstrated by the recording of the certificate of distribution, her assumption of exclusive possession of the property, her remarriage, and the construction of a new house on the land.” Id., 158. The principal holding in Ruick thus was based on a recognition that the plaintiff had knowledge that she was dispossessing her husband when she assumed exclusive possession of the property. The court further held that the plaintiffs adverse possession, which had begun against her then living husband, “continued against his other heirs, their daughters”; id., 160; and that, because the plaintiffs title by adverse possession was complete long before the children asserted any right to an interest in the property, they were barred from entry. Id., 160-61. Accordingly, Ruick merely held, with respect to the children, that, because they had failed to assert their rights in a timely manner, the plaintiff had acquired title by adverse possession. The court made no finding as to the effect of the children’s ignorance on the ultimate disposition of that case.

The dissent also mistakenly relies on Harrison. In that case, the issue before the court was whether the plaintiffs, who were claiming to own the land as tenants in common with the defendant, had lost the right to bring an action for partition of the property by sale because of the defendant’s exclusive possession of the property for many years; see Harrison v. Inter*595national Silver Co., supra, 78 Conn. 417, 419 (rendition of facts); and the court did not consider, or reach any conclusion regarding, the defendant’s knowledge as to its ownership of the property when the ouster commenced. See id., 419-22. Finally, although the dissent relies on language in Hagopian that “ [a] wrongful intent to disseize the true owner is not a necessary element of adverse possession”; Hagopian v. Saad, supra, 124 Conn. 259; we regard that case as an outlier and do not follow it for the reasons set forth in footnote 23 of this opinion.

A final problem with the dissent’s reliance on the foregoing cases is that none addresses the question, as the court did in Newell, of whether a cotenant without knowledge of the cotenancy may dispossess the other cotenant or cotenants. The dissent simply draws its own legal conclusions on the basis of the facts presented. Accordingly, we disagree with the dissent that adverse possession is not barred in cases in which the tenant in possession lacks knowledge of the cotenancy because no reviewing court has disavowed the principle articulated in Newell in the nearly 150 years since that case was decided, and one reviewing court has applied it.

A person’s mistaken belief that he or she is the lawful owner is immaterial in an action seeking title by adverse possession when the parties are not cotenants, as long as the other elements of an adverse possession have been established. See, e.g., Loewenberg v. Wallace, 151 Conn. 355, 357-58, 197 A.2d 634 (1964); Ahern v. Travelers Ins. Co., 108 Conn. 1, 5, 142 A. 400 (1928); Searles v. DeLadson, 81 Conn. 133, 135-36, 70 A. 589 (1908); Paletsky v. Paletsky, supra, 3 Conn. App. 588. This is because, unlike tenants in common, an adverse possessor in such a case has no legal right to possess the property, and, therefore, the possession itself is sufficient to claim title. In contrast, tenants in common have an equal right to possess the property. Thus, as we previously explained, a tenant in common who wishes to claim property by adverse possession must give the other cotenant clear and unmistakable notice of an intent to do so. The only Connecticut case stating otherwise is Hagopian v. Saad, supra, 124 Conn. 259, which relied on Searles v. DeLadson, supra, 136, in asserting that “[a] wrongful intent to disseize the true owner is not a necessary element of adverse possession.” The Hagopian court’s reliance on Searles, however, was improper, because the parties in Searles were not tenants in common, and the court in Searles was not discussing adverse possession in that context. Moreover, to our knowledge, no other appellate case involving cotenants has followed Hagop-ian's statement of the law on that issue. Accordingly, we regard Hagopian as an outlier.

We thus disagree with the dissent, which rejects Newell out of hand and contends that the plaintiffs mistaken belief that she was the sole owner of the lot has no effect on the analysis other than to lower her burden of proving intent and notice and to require “the defendant to indicate that she no longer intended to abide by the status quo” after the parties discovered in 1987 that there was a cloud on the title.

The dissent’s contention that the defendant’s unwillingness to sign the quitclaim deed supports, rather than undermines, the plaintiffs claim is inexplicable. As we indicated in the preceding discussion, there is no evidence in the record that the plaintiff informed the defendant in 1987 that she intended to dispossess the defendant if the defendant refused to sign the quitclaim deed. The only evidence in the record as to the parties’ intentions in 1987 is that the defendant refused to sign the quitclaim deed, thus indicating that the plaintiff was aware of the defendant’s ownership interest in the property and of the defendant’s intent to retain it.

We note that, although the trial court found that the lot was conveyed to the plaintiff by her mother in 1980 and that all of her children, including the plaintiff and the defendant, believed that their mother was the sole owner of the lot, that finding does not amount to a finding that the defendant was aware of the conveyance to the plaintiff. Thus, there are no factual findings of notice in 1980, when their mother conveyed her interest in the lot to the plaintiff.

The dissent’s characterization of such measures as “extreme” is itself extreme, as is its assertion that building a fence or posting “No Trespassing” signs around the property was unnecessary in light of the parties’ lack of communication over the past several decades. Footnote 8 of the dissenting opinion. It was because of the parties’ lack of communication that it was important for the plaintiff to give the defendant “clear and unmistakable” notice of her intent. Ruick v. Twarkins, supra, 171 Conn. 157. The dissent has not pointed to a single finding of fact, or set of facts, by the trial court that could reasonably be construed as an action “of such an unequivocal nature and so distinctly hostile to the rights of the other cotenants that the intention to disseize [was] clear and unmistakable.” Id. Accordingly, we disagree that the plaintiff would not have been required to demonstrate her intent by building a fence, posting signs or taking some other equivalent action.

We find it ironic that the dissent believes the defendant should have been aware of the so-called evidence of “constructive notice” of the plaintiffs intent to dispossess the defendant but steadfastly refuses to recognize that the certificate of devise or descent, which was recorded in the land records, did not give the plaintiff constructive notice that she was not the sole owner of the property. See PNC Bank, N.A. v. Kelepecz, 289 Conn. 692, 701, 960 A.2d 663 (2008) (“the purpose of the land records is to give constructive notice to the world of instruments recorded therein”); Kopylec v. North Branford, 130 Conn. App. 146, 163 n.18, 23 A.3d 61 (2011) (“It is well established . . . that [e]very person who takes a conveyance of an interest in real estate is conclusively presumed to know those facts which are apparent upon the land records concerning the chain of title of the property described in the conveyance .... The law implies notice on the ground that it is conclusively presumed that a person will not purchase an interest in a piece of land without examining the condition of the record. Such an act would be required by common prudence.” [Internal quotation marks omitted.]).

The dissent all too frequently departs from Connecticut precedent and repeatedly relies on an annotation published approximately fifty years ago; see W. Allen, annot., “Adverse Possession Between Cotenants,” 82 A.L.R.2d 5 (1962); which in turn relies on cases from other jurisdictions decided in the nineteenth and early twentieth centuries. Thus, to the extent that the annotation refers to any majority rule or trend in the case law, such a rule or trend does not reflect more current developments in the law over the last fifty years. In addition, the annotation contains only a handful of citations to Connecticut law, which we find significant in light of the dissent’s representation that the annotation is based on a review of more than “1100 American cases . . . .” Text accompanying footnote 9 of the dissenting opinion. Accordingly, the dissent would have this court apply principles relating to notice that in some instances are not only unfamiliar in this jurisdiction but are in conflict with established Connecticut law, such as the requirement articulated in Newell that actual intent to dispossess requires actual knowledge that the other cotenant has an equal right to possession. Newell v. Woodruff, supra, 30 Conn. 498-99.

Even if this principle has been recognized, which is arguable, it is not applicable here in light of the plaintiff’s concession that she gave notice to the defendant through the court and her attorneys when the prior litigation commenced in 1997.

John J. O’Connor also was a plaintiff at trial, but is not a party to this appeal. For convenience, we refer to Theresa P. O’Connor as the plaintiff.

It is not surprising that the trial court, in a prior case between the present parties involving virtually identical facts pertaining to two additional lots, concluded that the present defendant adversely possessed those two lots owned by the present plaintiff. See Larocque v. Percoski, Superior Court, judicial district of Tolland at Rockville, Docket No. CV-97-0063927-S (February 18, 2003). The majority explains why, in its view, the outcome of the prior case is not material to the present dispute between the parties. See footnote 6 of the majority opinion. Although I agree that the outcome of the prior case is unimportant for present purposes, the pleadings offered and the positions taken by the present defendant in that action are highly relevant here. Indeed, although it is true that the trial court in the present case rejected the plaintiffs “equitable” claim—that the plaintiff should succeed in her adverse possession action merely because the defendant successfully adversely possessed against her in the prior action—the court expressly left open the possibility that “certain aspects of the previous litigation among the parties may have a bearing on the resolution of the present suit, such as by way of collateral estoppel, judicial admissions or evidentiary admissions . . . .” (Emphasis added.) As I discuss in this dissenting opinion, it is in precisely that capacity that the trial court properly relied on the prior litigation in finding that the present defendant was on notice that the plaintiff was holding the lot adversely to her.

The majority, for example, concedes that under the clearly erroneous standard of review, it is the “duty [of] an appellate tribunal to review, and not to retry, the proceedings of the trial court.” (Internal quotation marks omitted.) Elsewhere in the opinion, however, the majority contends that “[i]t is the province of the . . . court ... to decide as a matter of law whether the facts found . . . fulfill the requirements of [adverse] possession,” and that “[a]pplication of the pertinent legal standard to the trial court’s factual findings is subject to our plenary review.” What is not clear is whether the majority considers the conclusion that a particular element of adverse possession such as notice or intent is satisfied in a given case to be a factual finding, subject to deferential appellate review, or, alternately, a legal conclusion, subject to de novo review. As I explain in footnote 5 of this dissenting opinion, the overwhelming weight of authority supports the former position. Of course, I do agree with the majority that, even under a deferential standard of review, reversal is warranted as a matter of law if: *610(1) there is no evidence to support the trial court’s factual findings; (2) the evidence is so slight that no reasonable fact finder could find the elements of adverse possession satisfied by clear and convincing evidence; or (3) the factual findings fail to satisfy the established legal standards for adverse possession. That is not the case here.

For adverse possession to lie, possession must be “actual, [open] and notorious, exclusive, continuous and hostile” throughout the statutory period. Ahern v. Travelers Ins. Co., 108 Conn. 1, 4-5, 142 A. 400 (1928); see also 3 Am. Jur. 2d 95-96, Adverse Possession § 10 (2002). In addition, in the case of adverse possession between cotenants, it is necessary to demonstrate that the cotenant in possession intended to hold adversely to the ousted cotenant, and that the latter was on actual or constructive notice of that intent.

This court has stated repeatedly that whether the constituent elements of adverse possession are satisfied is ultimately a question of fact, subject to deferential review. See, e.g., Caminis v. Troy, 300 Conn. 297, 306, 12 A.3d 984 (2011) (“our scope of review is limited . . . [bjecause adverse possession is a question of fact for the trier” [internal quotation marks omitted]); Goldman v. Quadrato, 142 Conn. 398, 404, 114 A.2d 687 (1955) (“Whether possession is adverse in character is a question of fact... . Since the [trial] court found all the essential elements of an adverse possession . . . the court was correct in its judgment.” [Citation omitted.]); Spencer v. Merwin, 80 Conn. 330, 336, 68 A. 370 (1907) (“[a]dverse possession is a question of fact, and when found by the trial court will not be reviewed by *611this court as a conclusion from evidential facts, unless it appears that these facts, or some of them, are legally or logically necessarily inconsistent with that conclusion” [internal quotation marks omitted]); White v. Beckwith, 62 Conn. 79, 82, 25 A. 400 (1892) (“[i]t is true that [the trial court] has found certain [evidentiary] facts . . . from the existence of which, if they had satisfied the mind of the trier, it was for him to find whether any entry had been made or possession taken and held under the deeds, and if so, whether such possession was actual, open, exclusive and hostile”); see also annot., 82A.L.R.2d301, § 86 (1962) (“questions whether in a given case [the essential elements of adverse possession between cotenants] are present are ordinarily issues of fact for the jury, and can become matters of law only when the evidence, or want of evidence, is conclusive”).

In particular, we have emphasized that the determination of whether the elements of adverse possession at issue in the present case—notice and intent—are satisfied is for the trier of fact. See Ruick v. Twarkins, 171 Conn. 149, 161, 367 A.2d 1380 (1976) (“[i]n the final analysis, whether [the plaintiffs] possession is adverse [to her cotenants] is a question of fact for the trier”); Lengyel v. Peregrin, 104 Conn. 285, 288, 132 A. 459 (1926) (“ouster ... is a question of fact”); Standard Co. v. Young, 90 Conn. 133, 137, 96 A. 932 (1916) (“The only contested question of fact in the case was . . . whether there had been an ouster of the [cotenant] defendants. This was a proper question for the jury.”); Bryan v. Atwater, 5 Day (Conn.) 181, 187 (1811) (whetherpossession was adverse to cotenant deemed “proper subject for the consideration of the jury,” unless by law only one result is possible, as where life tenant purports to possess adversely against lessor).

These statements are consistent with our general rule that intent and notice are questions of fact subject to deferential appellate review. See, e.g., State v. Hedge, 297 Conn. 621, 658-59, 1 A.3d 1051 (2010) (“[i]t is well established that the question of intent is purely a question of fact . . . the determination of which should stand unless the conclusion drawn by the trier is an unreasonable one” [internal quotation marks omitted]); State v. Hinton, 227 Conn. 301, 323, 630 A.2d 593 (1993) (“the trial court’s decision on the ultimate question of discriminatory intent represents a finding of fact . . . entitled to great deference” [citation omitted; internal quotation marks omitted]); Morin v. Bell Court Condominium Assn., Inc., 223 Conn. 323, 325, 612 A.2d 1197 (1992) (reviewing finding of constructive notice according to sufficiency of evidence standard); Lukas v. New Haven, 184 Conn. 205, 208, 439 A.2d 949 (1981) (“[wjhether the plaintiff sustained his burden of proof on the [issue] of . . . constructive notice . . . presented [a question] of fact for the trier to determine upon all the evidence”); Baker v. Ives, 162 Conn. 295, 307, 294 A.2d 290 (1972) (“constructive notice is a question of fact for the jury and unless . . . [only] one conclusion could be found, its determination should be left to the trier”). None of the adverse possession cases cited by the majority is to the contrary, and the majority offers no rationale for reviewing findings of notice and intent differently in *612adverse possession cases than in every other area of this court’s jurisprudence.

To the extent that the majority relies on Bristol v. Tilcon Minerals, Inc., 284 Conn. 55, 931 A.2d 237 (2007), an inverse condemnation case, for the proposition that plenary review of the trial court’s factual conclusions is warranted in the present case, its reliance is misplaced. In Bristol, we repeated, as we have on numerous other occasions, that a “trial court’s conclusions must stand unless they are legally or logically inconsistent with the facts found or unless they involve the application of some erroneous rule of law material to the case.” (Emphasis added; internal quotation marks omitted.) Id., 83. This language is by its very nature deferential, in that it requires a reviewing court to uphold a trial court’s conclusions unless, as a matter of law, they could not flow from the factual record. Indeed, in the more than sixty cases in which we used the quoted language prior to Bristol, we never once equated it with a plenary or de novo standard of review. To the contrary, the language frequently appears in the context of reviewing the sufficiency of a trial court’s factual conclusions, where it is clear that our standard of review is deferential. See, e.g., AFSCME, Council 4, Local 704 v. Dept. of Public Health, 272 Conn. 617, 622-23, 866 A.2d 582 (2005) (“Waiver is a question of fact. . . . [Wjhere the factual basis of the court’s decision is challenged we must determine whether the facts set out in the memorandum of decision are supported by the evidence or whether, in light of the evidence and the pleadings in the whole record, those facts are clearly erroneous. . . . Therefore, the trial court’s conclusions must stand unless they are legally or logically inconsistent with the facts found or unless they involve the application of some erroneous rule of law material to the case.” [Citations omitted; internal quotation marks omitted.]); Newbury Commons Ltd. Partnership v. Stamford, 226 Conn. 92, 99-100, 626 A.2d 1292 (1993) (“The trial court was presented with conflicting testimony as to the value of the property, and concluded that the report and testimony of the plaintiffs expert was the most credible. In any assessment case in which the trial court is confronted with conflicting appraisal methods, it is a proper function of the court to give credence to one expert over the other. . . . The conclusions reached by the trial court must stand unless they are legally or logically inconsistent with the facts found or unless they involve the application of some erroneous rule of law. ... We will not disturb the trial court’s adoption of the plaintiffs valuation of the property, therefore, unless the appraisal was legally invalid.” [Citations omitted; internal quotation marks omitted.]); Horton v. Meskill, 172 Conn. 615, 639, 376 A.2d 359 (1977) (“A finding is to be read to uphold the judgment. Every reasonable presumption will be indulged in to support it. . . . The conclusions reached by the trial court must stand unless they are legally or logically inconsistent with the facts *614found or unless they involve the application of some erroneous rule of law material to the case.” [Citations omitted; internal quotation marks omitted.]); Esposito v. Commissioner of Transportation, 167 Conn. 439, 440-41, 356 A.2d 175 (1974) (“The defendant has . . . made a wholesale attack on the referee’s flnding[s] [of fact]. Such an attack on a finding rarely produces beneficial results and in effect the defendant seeks to have this court retry the issues. This is not our function. . . . The conclusions reached by the trier must stand unless they are legally or logically inconsistent with the facts found or unless they involve the application of some erroneous rule of law material to the case.” [Citation omitted.]); Southern New England Contracting Co. v. State, 165 Conn. 644, 651-52, 345 A.2d 550 (1974) (“These conclusions are to be tested by the finding, as corrected. . . . They must stand unless they are legally or logically inconsistent with the facts found or unless they involve the application of some erroneous rule of law material to the case. . . . The wisdom of these policies is pointed out with particular force by a case such as this where the factual framework is extremely complex and where, as the trial court pointed out, there were sharp conflicts in the evidence.” [Citations omitted; internal quotation marks omitted.]). Accordingly, to the extent that we suggested in Bristol that this court engages in a plenary review of the sufficiency of the evidence to support a trial court’s factual conclusions, that statement was inconsistent with the weight of our case law.

Although the cases are inconsistent in their use of the term “ouster,” at times equating it with a physical eviction of the rightful owner, and at other times equating it with adverse possession in general, in this dissenting opinion I use the term merely to refer to the additional elements of intent and notice necessary to establish adverse possession among cotenants.

Although the majority disputes the contention that it requires something closely akin to express notice, the examples it offers of how the plaintiff might have notified the defendant of her intent to hold the lot exclusively are, in fact, extreme measures, such as enclosing this small, undeveloped rural lot within an impassable barrier and surrounding it with no trespassing signs. The majority also concludes its analysis by declaring that “there is absolutely no evidence . . . that the plaintiff expressly notified or conveyed a clear and unmistakable intent to disseize the defendant . . . .” (Emphasis added.) It is clear from the authorities cited in this dissent that such extreme measures are not necessary, especially in a case such as this, where there has been virtually no communication between the parties over the past three decades, during which time the defendant never once entered onto the lot or contributed to its upkeep in any way.

*616It also bears noting that, while the majority appears to believe that a claimant must take some affirmative step to give her cotenant notice of her intent to hold exclusively, the very authorities cited by the majority make clear that giving notice is unnecessary; all that is required is that the ousted cotenant have notice of the adversity of the claimant’s possession. See, e.g., Ruick v. Twarkins, supra, 171 Conn. 158 (there also must be proof of “an ouster and exclusive possession so openly and notoriously hostile that the cotenant will have notice of the adverse claim” [emphasis added]).

E. Orr, comment, “Adverse Possession Against Tenants in Common in Tennessee,” 37 Tenn. L. Rev. 776, 793 n.84 (1970) (citing Allen’s annotation in 82 A.L.R.2d 5 and recognizing Allen’s review of 1100 cases); see also Shives v. Niewoehner, 191 N.W.2d 633, 637 (Iowa 1971) (“excellent annotation”); Wengel v. Wengel, 270 Mich. App. 86, 98, 714 N.W.2d 371 (2006) (“[t]he law of adverse possession as between cotenants is thoroughly discussed in [Allen’s annotation in] 82 A.L.R.2d 5”); McCann v. Travis, 63 N.C. App. 447, 451, 305 S.E.2d 197 (1983) (referring readers to Allen’s annotation for unique set of rules governing adverse possession between cotenants); Nelson v. Christianson, 343 N.W.2d 375, 378 (N.D. 1984) (praising Allen’s work as “exhaustive annotation”); Caywood v. January, 455 P.2d 49, 51 (Okla. 1969) (“exhaustive” annotation); Silver Surprize v. Sunshine Mining Co., 15 Wn. App. 1,32 n.11, 547 P.2d 1240 (1976) (McInturff, C. J., dissenting) (“extensive annotation”); J. Legg, “Real Property Actions and Proceedings Law Section 541: The Mind-Buster Busted,” 59 Alb. L. Rev. 1485,1516 n. 198 (1996) (“broad discussion of adverse possession between co-tenants”). To its credit, the trial court relied on Allen’s annotation in concluding that the plaintiff satisfied the legal requirements for adverse possession against a cotenant. The majority, by contrast, inexplicably dismisses a treatise that courts and legal scholars continue to recognize as the definitive source on the topic. While the majority rejects Allen’s work for having been “published . . . fifty years ago,” in fact the annotation has been recently updated and indicates no shift in the majority position that constructive notice of the intent to dispossess a cotenant may be given in myriad ways, and is to be determined by the trier of fact based on the unique circumstances of each case. See annot., supra, 82 A.L.R.2d 5, as updated by the Later Case Service (2001) §§ 40, 52, 53, 60 and 62. Nor does the majority offer any evidence that the prevailing rule established over the course of hundreds of years of common law has suddenly changed in recent years. As to the majority’s contention that Allen’s compendium reflects a statement of the law “unfamiliar in this jurisdiction,” I would emphasize that every theory of constructive notice for which I cite Allen’s annotation has been embraced, either expressly or implicitly, by appellate courts in Connecticut.

Allen is in good company. Later Chief Justice Taft, writing for the United States Court of Appeals for the Sixth Circuit, reached the identical conclusion in Elder v. McClaskey, 70 F. 529, 542-43 (6th Cir. 1895): “There are some authorities in which language is used indicating that, before a tenant in common can hold adversely to his cotenants, he must prove that his coten-ants had actual knowledge of his intention to assume exclusive possession, but it will be found that the language was not necessary to the decision of the cases under consideration. ... By the overwhelming weight of authority .. . actual notice is not necessary . . . .” (Citation omitted.)

Perhaps unsurprisingly, the majority concludes that the present case is more akin to White v. Beckwith, 62 Conn. 79, 83, 25 A. 300 (1892), the lone case, to my knowledge, in which this court has found against a cotenant purporting to adversely possess against his tenants in common. It is noteworthy, however, that in Beckwith this court did not find that the plaintiff could not, as a matter of law, have adversely possessed the contested property. Rather, this court clarified that the trial court could have found adverse possession on the facts of that case, but we deferred to the trier’s conclusion that the plaintiffs possession was not in fact adverse to the defendants. Id., 82-83. Here, the trial court found otherwise, and I would likewise defer.

The majority’s statement that “only five [of the nine cases decided by this court or the United States Supreme Court] have been decided in favor of the claimant” is somewhat misleading, given the fact that all nine cases made clear that a finding of adverse possession would have been legally permissible.

The majority posits that these theories of constructive notice: (1) have not been adopted by Connecticut courts; (2) were neither raised at trial by the plaintiff nor considered by the trial court; and (3) are precluded by the plaintiffs alleged admission that the defendant was not on notice of her intent to hold the lot exclusively until 1997. These claims are simply untrue.

First, each theory has been embraced, at least implicitly, under Connecticut law. Indeed, of the three theories, the second, which focuses on lengthy acquiescence by the ousted cotenant, is conceded by the majority to be an accepted part of Connecticut law, and the third theory, which looks to the totality of the circumstances, is not really a distinct theory at all but merely the unexceptional proposition that the trier of fact may find that a cotenant is on notice wherever the unique circumstances of the case reasonably support that conclusion. Although the majority and I may differ as to what circumstances would constitute clear and convincing evidence, the majority, having conceded that constructive notice of adverse possession is possible, can hardly disclaim the principle that such notice is to be ascertained by the trier of fact on the basis of the circumstances of the case.

Second, the plaintiffs attorney did elicit testimony in support of these theories at trial. Indeed, the plaintiff herself emphasized that her claim of exclusive possession was based not only on a long history of sole possession and acts of ownership, without contribution from the defendant, but also on the fact that all parties believed that she had acquired full title to the lot in 1980.

In addition, the trial court made the necessary factual findings to support a conclusion that: (1) the plaintiff took the lot in 1980 under color of title, with the full knowledge of the defendant; (2) neither party at the time was aware of the defendant’s interest in the lot; (3) over the ensuing twenty-seven years the plaintiff acted as if she were the exclusive owner of the lot, without interference from the defendant; and (4) other unique circumstances of the case, in tandem with the plaintiffs more credible testimony, made clear that the defendant was aware that the plaintiff intended to hold the lot as the exclusive owner. It is true that the trial court’s ultimate conclusions are couched in general terms, alluding to the “bitter relationship” and “history between” the parties, and the “unique facts” of the case, and that it did not pin on its findings the precise labels I have used in this dissenting opinion. It might have been preferable for the court to have cited to all of the case law referenced herein, or to have connected the dots more directly between its evidentiary findings and its ultimate conclusion that the elements of adverse possession were satisfied, but there is no such requirement. Rather, where the sufficiency of the evidence to support the verdict is challenged on appeal, the reviewing court must “give the evidence the most favorable reasonable construction in support of the verdict . . . .” (Internal quotation marks omitted.) Kimberly-Clark Corp. v. Dubno, 204 Conn. 137, 153-54, 527 A.2d 679 (1987). Moreover, where a memorandum of decision is ambiguous, this court is not precluded from affirming the judgment on a basis not expressly cited by the trial court. See Skuzinski v. Bouchard Fuels, Inc., 240 Conn. 694, 703, 694 A.2d 788 (1997); Wenzel v. *620Danbury, 152 Conn. 675, 676-77, 211 A.2d 683 (1965). Here, it strains credulity for the majority to suggest that, when all reasonable inferences are drawn in favor of the verdict, there was literally no evidence to support the court’s determination that the defendant knew that the plaintiff was holding the lot adversely to her.

Lastly, the majority relies heavily on its finding that the plaintiff herself conceded that she did not give notice of her intent to dispossess the defendant until 1997. Initially, I note that the trial court did not make this finding, and that it is not our role to do so. In re Jorden R., 293 Conn. 539, 559 n.17, 979 A.2d 469 (2009). Moreover, the majority discerns this allegedly dispositive concession solely from the fact that, when asked on cross-examination how she could have told the defendant that she was adversely possessing the lot when they were not on speaking terms, the plaintiff replied: “Through court and lawyers. When ... the question of the other two lots came up ... it was brought up.” There is literally nothing in this testimony to support the view that the plaintiff never provided any notice to the defendant prior to 1997, or that not only did the plaintiff not tell the defendant of her adverse intentions until 1997, but that none of her actions prior to that time afforded her sister even constructive notice thereof. The question to the plaintiff was not “when did you first tell her?” or even “when did you tell her?” It was “how did you tell her . . . ?” (Emphasis added.) There is no indication, given the context of the question, that the reply elicited or offered was intended to speak to the issue of when the plaintiff first sought to notify the defendant of the adversity of her holdings. Moreover, even if 1997 were the first time that the plaintiff actively sought to give the defendant notice, the relevant legal question is not when the plaintiff gave notice but, rather, when the defendant had notice. See footnote 8 of this dissenting opinion. The fact that the plaintiff told the defendant something in 1997 says absolutely nothing about what constructive notice the defendant might have had prior to that time. To construe this one statement by the plaintiff as a broad concession that she failed to satisfy the elements of adverse possession, and to credit it over her explicit testimony to the contrary, runs afoul of this court’s long-standing commitment to “give the evidence the most favorable reasonable construction in support of the verdict . . . .” (Internal quotation marks omitted.) Assn. Resources, Inc. v. Wall, 298 Conn. 145, 185, 2 A.3d 873 (2010).

Similarly, from one brief reference to the parties’ “prior acrimonious litigation” in the memorandum of decision, the majority concludes that the trial court relied on the prior litigation as the primary basis for its conclusion that the plaintiff held the lot adversely to the defendant, and that its decision was therefore clearly erroneous. The majority gives no credence to the various other factors discussed by the trial court in its memorandum of decision and articulation, including: the history between the parties; their bitter relationship and twenty-five years of not speaking; the fact that the defendant never claimed an ownership interest in the lot; the deeding of the lot to the plaintiff; the defendant’s lack of credibility; and the plaintiffs general use of the lot as an exclusive owner. Nor does the majority consider the possibility that in referencing the prior litigation, the court was simply crediting the suggestion by the plaintiffs counsel during closing argument, that the defendant cannot plausibly deny that she was on notice when she *621essentially alleged in her own action that the same adversity had existed since at least 1982. In short, I see no indication that the majority has tried to give the evidence, and inferences drawn therefrom, the most favorable reasonable construction in support of the verdict, as required by our law.

Although I agree with the majority that the quitclaim deed in Lucas conferred stronger color of title than the deed in the present case, I believe that Lucas nevertheless established the broader proposition that taking under color of any quitclaim deed can provide at least some indication of the grantee’s intent to hold the property exclusively.

The majority also suggests, in footnotes 19 and 25 of its opinion, that I am ignoring “an essential legal fact of significance,” to wit, that in the present case the land records contained a certificate of devise or descent indicating that Doris Percoski, the mother of both the plaintiff and the defendant, only acquired one third of the lot upon the passing of her husband. The plaintiffs action alleges a claim of adverse possession, not a claim of rightful ownership. To establish adverse possession, she need not prove that she had a legal right to the lot, or even that she had a reasonable belief that the lot was hers. She need only prove that she intended to hold the lot exclusively. The fact that she took the lot under color of a deed that she believed gave her full title demonstrates that intent to hold the lot as her own, regardless of how reasonable or unreasonable that belief might have been. In addition, the plaintiff must prove that the defendant, her cotenant, was on notice of her intent to hold the lot exclusively. Again, if the defendant believed that *623the plaintiff had acquired full title from their mother, and if she knew that the plaintiff also believed that, then the defendant was on notice of the plaintiff’s adverse intent. The fact that either party easily could have discovered the truth by inspecting the land records would be relevant to a claim of rightful legal ownership but has no bearing on the questions at issue here.

The majority, while attempting to distinguish Lucas from the present case, neglects to discuss any of the other Connecticut cases or the cases from other jurisdictions that I cite in this dissenting opinion, which support the commonsense rule that a quitclaim deed can confer color of title sufficient to support a claim of adverse possession when all parties believe that the deed conveys exclusive title. Moreover, even setting aside my disagree*624ment with the majority as to the scope of the rule established by Lucas, Cady and Rogers, it is clear that no Connecticut case has ever held that a quitclaim deed such as the one in the present case cannot provide color of title sufficient to ground a claim of adverse possession.

See, e.g., Pebia v. Hamakua Mill Co., 30 Haw. 100, 109 (1927) (“[t]his court has always held that evidence of ouster or the adverse character of a claim must be much clearer as between co-tenants than as between strangers, but it has never gone so far as to hold that . . . the more stringent rule applicable to cases of co-tenancy applies where there is no recognition or knowledge of the existence of a co-tenancy”); Chambers v. Wilcox, 1905 Ohio Misc. LEXIS 48, *10-13 (Ohio Common Pleas January 16,1905) (quieting title in plaintiff cotenant in ignorance, notwithstanding usual Ohio rule that cotenants may only adversely possess against other cotenants through overt, *626unmistakable acts of ouster, because where all parties had proceeded for years on assumption that plaintiff was exclusive owner, there had been no need or cause for him to notify defendants of his intention to continue in that capacity).

The majority contends that Newell v. Woodruff, 30 Conn. 492 (1862), a case in which adverse possession was not even at issue, holds that ouster is not possible between cotenants in ignorance. I disagree. Newell was an action seeking damages for ejectment, predicated solely on vague letters the plaintiffs attorney had sent to the defendant, suggesting without proof or specificity that the plaintiff was “ ‘perhaps’ ” entitled to possession of a part of the property. Id., 499. In affirming the trial court’s granting of nonsuit, we explained that it would be unjust to subject the defendant “to the cost and damage demanded in an action of disseizin” without first: (1) detailing the basis of the plaintiffs claims; (2) formally requesting possession of the land; and (3) affording the defendant an adequate opportunity to grant or deny access. Id., 498. Accordingly, although the case does suggest that knowledge of one’s cotenant status is necessary for dispossession to occur, it does so in the specific context of an ejectment action, where it would be unjust to penalize the party in possession for disseizing a cotenant whom she never knew existed and had never actively barred from possession. In other words, the court, quite reasonably, imposed a mens rea requirement before a cotenant may be found liable for damages resulting from an alleged ouster. See Giannattasio v. Silano, 115 Conn. 299, 302, 161 A. 336 (1932) (Newell stands for proposition that “[wjhere a person is occupying premises as his own, in the belief that he has an exclusive title, and in ignorance of the rights of another person as tenant in common, it is unreasonable that he should be subjected to the cost and damage demanded in an action of disseizin, until the demandant has apprised him with reasonable precision of the nature of his claim” [internal quotation marks omitted]).

There is no indication in NeweU that the court would have applied the same standard where a party in long possession seeks merely to quiet title in herself. The majority asserts that the close relationship between actions for ejectment and actions for adverse possession—both revolve around a claim of disseisin—means that language from the NeweU opinion, and its syllabus, necessarily applies to adverse possession as well as to ejectment. Although it is true that ejectment and adverse possession are two sides of the same coin, the difference between heads and tails is not always insignificant. In the case of NeweU, the cited language only makes sense in the unique context of an ejectment action, where a party is subject to damages. It would be perverse, to say the least, if, as the majority suggests, the law were to require a wrongful intent before rewarding a party with legal title to land.

Even if there were a legal requirement that cotenants be aware of the cotenancy before ouster can occur, which I believe there is not, it would still be true that a cotenant may be ousted once the cotenancy is discovered, and that in such cases ouster may be more readily established than when *627the parties knew of the cotenancy from the outset. In a cotenancy that arises with the knowledge of ail parties, the status quo involves an expectation that one cotenant possesses with the consent and for the benefit of all, so that a cotenant seeking to possess exclusively bears the burden of notifying his cotenants thereof. By contrast, when the status quo has been such that both parties believe the cotenant in possession to be the exclusive owner, and when that parly’s relationship to the land and the other cotenants does not change upon their discovery of the cotenancy, the most reasonable assumption under the circumstances may be that the possession remains adverse. See Ricard v. Williams, supra, 20 U.S. 116; Lucas v. Crofoot, supra, 95 Conn. 626; Bryan v. Atwater, supra, 5 Day (Conn.) 191. In that case, the burden shifts to the ousted cotenants actively to press their possessory rights, consistent with the holding in Newell that the allegedly ousted coten-ant bore the burden of clearly asserting his right to the land. Newell v. Woodruff, supra, 30 Conn. 498.

The majority, having alleged that Connecticut law unequivocally bars adverse possession between cotenants in ignorance, relies on a single Superior Court opinion; see Diamond v. Boynton, 38 Conn. Sup. 616, 618, 458 A.2d 18 (1983); to dismiss all four cases in which this court found, or permitted a trial court to find, adverse possession under precisely those circumstances. I fail to understand the majority’s reasoning here. The argument appears to be that the purported Newell rule does not apply under the “special circumstances” where the cotenant in possession holds under color of title. But that theory is fundamentally inconsistent with the majority’s reading of Newell. If, as the majority contends, Newell stands for the proposition that ouster of a cotenant is possible only when the party in possession knowingly and wrongly intends to dispossess his cotenants, then why should that rule not apply when his is the only name on the land records? This flies in the face of the very language from Newell on which the majority relies: “[T]here can be no . . . adverse holding, where one is *628in the eqjoyment of that which he honestly supposes is his Newell v. Woodruff, 30 Conn. 492, 498 (1862).

I would further emphasize that in the cases in which this court has permitted a finding of adverse possession among cotenants in ignorance, the court’s reference to the land records was merely by way of noting that the possessory cotenant held the property under color of title. That is precisely my claim in this case. Although it is true that in the present case the plaintiffs name was not the only name on the land records, there was undisputed testimony at trial that neither the plaintiff nor the defendant was aware of that. Because the law is clear that ouster requires only that the parties believe that the would-be adverse possessor is holding exclusively, that is a distinction without a difference.

The majority’s further efforts to distinguish the four subsequent cases in which this court has implicitly rejected the purported Newell rule are unavailing. First, the majority contends that Ruick v. Twarkins, supra, 171 Conn. 168, was not in fact a case of cotenants in ignorance, because the plaintiff in that case knew that she had defrauded her husband of his share in the land. The majority ignores the fact that the case was not between the plaintiff and her late husband. Rather, the defendants were three of their four daughters, who, as in the present case, had unknowingly acquired their father’s share through the law of intestate succession. Id., 151. The opinion makes quite clear that the plaintiff did believe that she was the sole owner of the property upon her husband’s death, and that she was not aware of her daughters’ claims until the statutory period for adverse possession had passed. Id., 154-55, 159.

Second, the majority contends that in the case of Harrison v. International Silver Co., supra, 78 Conn. 417, the court did not reach any conclusion as to the defendant adverse possessor’s knowledge of his ownership of the property when the ouster commenced. Although it is true that the court in Harrison never expressly stated that the defendant held the land in ignorance of the cotenancy, the facts of the case, as recited by the court, make it clear that the defendant could not have been aware of the cotenancy. The land in Harrison was conveyed in 1873 by the plaintiffs’ guardian by a deed reciting that he was duly authorized to make such conveyance by an order of the Court of Probate. Id., 418. The plaintiffs themselves did not discover until 1886 that certain defects in the appointment of the guardian rendered the 1873 conveyance invalid, and they did not inform the defendant until sometime between 1898 and 1900. Id. On the defendant’s side, the land had passed from the 1873 purchaser to the defendant through a series of conveyances, including a mortgage foreclosure. Id. Given that record, if there were a rule barring adverse possession among cotenants in ignorance, the court surely would have addressed the matter.

Third, in the case of Standard Co. v. Young, supra, 90 Conn. 133, the majority relies on the fact that this court did not decide whether there had been an ouster, but rather remanded the case for a jury trial. The majority misses the point here. The trial court in Young found that the plaintiff, a cotenant in ignorance, had acquired the disputed property by adverse possession. This court, on appeal, while assuming that adverse possession had been properly found, remanded the case because it had been improperly tried to the court rather than before a jury. Id., 138-39. If, however, the *629majority was correct in its view that, as a matter of law, adverse possession is impossible as between cotenants in ignorance, the court in Young would have neither assumed that adverse possession was properly found nor remanded the matter for a jury trial, because the plaintiff could not ultimately have prevailed.

Finally, the majority declares the remaining case, Hagopian v. Saad, supra, 124 Conn. 256, to be an “outlier.” This conclusion is problematic because Hagopian, a cotenant case decided more than seventy-five years after Newell, explicitly states that “[a] wrongful intent to disseize the true owner is not a necessary element of adverse possession.” Hagopian v. Saad, supra, 259. Where an express statement of the law in a later case conflicts with what can at best be described as an implied legal principle contained in an earlier case, it seems odd to say that the later, more explicit case is the outlier. Adopting the majority’s view of the law requires not only reading into Newell a legal rule that is inconsistent with the court’s reasoning in that case, but also ignoring the law as we have subsequently stated and applied it over the past century.

The majority emphasizes that the plaintiff and her husband appear to have planted trees in the early 1980s so as to wall off the lot from their own home. The record does not reveal their original intent in this regard, or whether, for instance, they initially may have planned to delineate the lot boundaries so as to facilitate its later sale to a third party. In any event, throughout the course of litigation between the parties, it has never been suggested that the plaintiff was aware of the cotenancy prior to 1987.

The plaintiffs complaint refers to the memorandum of decision from the prior litigation in which the trial court concluded that “the evidence supports a finding that all parties believed [Doris Percoski] was the owner” of Constanty Percoski’s lands. Larocque v. Percoski, Superior Court, judicial district of Tolland at Rockville, Docket No. CV-97-0063927-S (February 18, 2003).

The assessment records of the town of Somers identified only the plaintiff and her husband as the owners of the property.

In the face of the plaintiffs clear trial testimony that her claim of adverse possession is based on the fact that all parties believed that she had acquired sole possession of the lot in 1980 and that she had acted as though she were the sole owner from that time forth, I am at a loss to understand the majority’s continued insistence that there is “no evidence in the record that the plaintiff had the requisite intent [to exclude the defendant] in 1987,” or that it is the plaintiffs position that the defendant was not on notice thereof until 1997.

The plaintiffs claim to hold the lot under color of title is not negated by the fact that, upon discovering the cloud on the title in 1987, she sought, with varying success, to obtain her siblings’ interests therein. Because the law encourages the peaceable and expeditious resolution of property disputes, efforts to settle such disputes need not undermine a claim of exclusive ownership. Annot., supra, 82 A.L.R.2d §§ 81 and 84; Ruick v. Twarkins, supra, 171 Conn. 154 (affirming trial court’s finding of adverse possession where plaintiff had asked defendants to sign papers relating to their interests in land); Bryan v. Atwater, supra, 5 Day (Conn.) 186 (finding adverse possession where plaintiff subsequently acquired quitclaim deeds from three of five cotenants). In its articulation in the present case, the trial court expressly found that the plaintiff sought and—in some cases—obtained her siblings’ interests in the lot “in an effort to reach a settlement of the property issues between the parties” and not as “an admission of ownership . . . .” This was a question of fact, on which we must defer to the trier. Annot., supra, 82 A.L.R.2d § 84. Moreover, the defendant’s unwillingness to grant her share of the lot to the plaintiff supports, rather than undermines, the plaintiffs claim, because it indicates the hostility of the plaintiffs possession. See Bryan v. Atwater, supra, 189 (“[i]f [the possession] be without the [owner’s] consent, and against his will, it is adverse”).

In fact, we adopted Prosser in the earlier case of Bryan v. Atwater, supra, 5 Day (Conn.) 188.

See annot., supra, 82 A.L.R.2d 134 (“[t]he initial, and leading, decision, recognizing, defining, and applying the principle of presumed or inferred ouster, is [Prosser]'").

Although I agree that the fact that the property in Camp was actively used as a parsonage strengthened the defendants’ claim of ouster, nothing in that case indicates that such a specific use of the land is a precondition for applying the Prosser rule. Similarly, in Bryan v. Atwater, supra, 5 Day (Conn.) 188, although the property in question was in fact developed land, this court recited the Prosser rule in quite general terms, without any reference to the use of the property: “[I]f one tenant in common, has been in possession a great number of years, without any accounting to his fellow commoners, this is proper evidence, from which the jury may infer an adverse possession.” Nothing in Bryan suggests that, in adopting Prosser as Connecticut law, this court imposed an additional requirement that the land be used for any particular purpose. Bather, the court suggested that the Prosser rule is simply an example of the general principle, equally applicable to landlord-tenant law, that “[i]f [possession] unaccompanied with any other acts . . . has been of long standing, without accounting for the rents and profits, it may be evidence to the jury, of an adverse possession.” Id.

In Bryan, the plaintiffs and their siblings inherited the land in question from their father on his death. Several years after entering the land pursuant to a bond, the defendant’s predecessors obtained by quitclaim deed the interests of the father’s widow and two of the four siblings, but the plaintiffs refused to relinquish their interests. Bryan v. Atwater, supra, 5 Day (Conn.) 182-83 (recitation of facts).

Indeed, in Prosser itself several justices implied that a briefer occupancy could have supported the result. See Doe ex dem. Fishar v. Prosser, supra, 98 Eng. Rep. 1053-54 (Ashhurst, J.) (implying that jury might have found ouster based on twenty-six years of possession); id., 1053 (Mansfield, Lord) (relating case to hypothetical in which tenant pur autre vie holds over for twenty years).

In Hewitt v. Beattie, 106 Conn. 602, 610, 138 A. 796 (1927), we cited Ricard among a list of “our decisions . . . .” See also Hewitt v. Sanborn, 103 Conn. 362, 372, 130 A. 472 (1925) (relying on Ricard for Connecticut law).

Significantly, even though the prior litigation took place in 1997, the defendant’s allegations in that prior case, on which the plaintiff and the trial court relied in the present case, hearkened back to 1980. In other words, if the defendant claimed in 1997 that her holding had always been openly hostile to the plaintiff, then she cannot contend that she had been unaware that the plaintiffs mirror-image holding was likewise hostile to her during that same time period.

In closing argument, the plaintiffs counsel specifically referenced the history of litigation between the parties as evidence that the defendant must have been on notice of the plaintiffs hostile intent, and further noted that the defendant must have been aware of the plaintiffs claims based on the defendant’s own position in the prior action. It is therefore reasonable to infer that the court had this theory of the case in mind in finding that ouster had occurred.