In part, the way the West was won was by the employment of the device of adverse possession. Adverse possession is a method of acquiring legal title to real property simply by possessing it for some statutory length of time. To acquire real property by adverse possession, there must be proof of non-permissive use. To acquire realty by adverse possession, the possessor’s occupation must also be actual, open, notorious and exclusive and must continue for the statutory period. What is laudatory about adverse possession is that the adverse possessor is rewarded for making nonproductive or fallow land productive.