For this example, let’s say you live next door to your in-laws and you’ve created a garden that overlaps onto their property. You’ve taken care of the plants for years and everyone is aware that this is your garden.
At first look, this might be a successful claim. But some courts have ruled that adverse possession between family members won’t be successful because of implied consent. Because it’s between family members, the property owner may not mind if their relative borrows the land, so it doesn’t meet the hostile criteria.