The Maryland Court of Appeals held in Breeding v. Koste that the “woodlands exception” applied in cases involving prescriptive easements also applies to adverse possession where the land at issue is unimproved or otherwise in a general state of nature. The exception holds that in such circumstances, there is a legal presumption that the claimant’s use is by the owner’s permission, thus defeating a claim of adverse possession. The Court then held that “unimproved land is undeveloped land that lacks additions that increase the land’s value or utility or enhance the land’s appearance.” Under that definition, the Court determined that the woodlands exception did not apply in this case because certain improvements had been made to the property at issue, including a road, a storage box, duck blinds, and “no trespassing” signs, and those improvements were sufficient to put the owner of the property on notice of the adverse use. A link to the unanimous May 22, 2015 opinion by Judge Watts is here