Showalter v. Pantaleo, 9 A.3d 233

Appellants Showalter purchased 424 West Main St. in 1979 and began maintaining adjacent vacant lot owned by LTV Steel.
The lot was used for gardening, trees, a kiddie pool, swing set, dog and child play areas, and trailer parking for ~30 years with no evidence of permission from LTV.
LTV filed bankruptcy on July 17, 1986; bankruptcy estate later acquired and transferred the lot via chain to Bet-Tech and finally to Pantaleo in 2008.
Appellants filed suit for adverse possession after Bet-Tech sold to Pantaleo; trial court found no 21-year continuous possession due to interruption.
Trial court relied on bankruptcy interrupting continuity of possession; decision ultimately favored Pantaleo after post-trial motion.
Pennsylvania law requires actual, continuous, exclusive, visible, notorious, distinct and hostile possession for 21 years; bankruptcy can interrupt continuity.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does bankruptcy of the record owner interrupt continuity for adverse possession?	Showalter argues continuity is defeated only by possessor's action, not owner's bankruptcy.	Pantaleo contends bankruptcy interrupts possession continuity under applicable law and authorities, preventing 21-year accumulation.	Yes; bankruptcy interrupts continuity, defeating adverse possession claim.

General Iron Ind., Inc. v. A. Finkl & Sons Co., 226 Ill. Dec. 652, 686 N.E.2d 1 (Ill. App. 1997) (landowner bankruptcy interrupts continuity of possession)
Coppard v. Stanush, 258 S.W. 254 (Tex. Civ. App. 1924) (bankruptcy petition interrupts adverse possession)