We apply a six-part test for determining whether adverse possession has occurred: "for possession to be adverse it must be (1) under claim of ownership; (2) actual or hostile; (3) open, notorious, and visible; (4) continuous and uninterrupted for a period of ten years; (5) exclusive; and (6) peaceful." Walker v. Murphree , 722 So.2d 1277, 1281 (¶ 16) (Miss. Ct. App. 1998). The burden was on Orcutt to prove each element by clear and convincing evidence.

" Walker v. Murphree, 722 So.2d 1277, 1281 (¶16) (Miss. Ct. App. 1998). This Court has held that "[a]dverse possession of 'wild' or unimproved lands may be established by evidence of acts that would be wholly insufficient in the case of improved or developed lands."

Id . Generally, a finding that proof was sufficient to sustain an adverse-possession claim is a finding of fact and requires the application of the substantial-evidence/manifest-error rule. Id . (citing Walker v. Murphree , 722 So.2d 1277, 1280 (¶ 15) (Miss. Ct. App. 1998) ).DISCUSSION

Id. A finding that the proof was insufficient to sustain a claim of adverse possession is a fact-finding that requires our application of the substantial evidence/manifest error test. Walker v. Murphree, 722 So.2d 1277, 1280 (¶ 15) (Miss.Ct.App. 1998). If substantial evidence supports the chancellor's fact-findings, this Court must affirm, even though we "might have found otherwise as an original matter." Nichols, 883 So.2d at 556 (¶ 7). and where the j chancellor has failed to make specific findings, we will assume that the chancellor resolved such issue in favor of the appellee.

Id., (quoting Lynn v. Soterra, Inc., 802 So.2d 162, 167 (¶ 17) (Miss.Ct.App. 2001)). ¶ 20. For example, in Walker v. Murphree, 722 So.2d 1277, 1281-82 (¶¶ 16-20) (Miss.Ct.App. 1998), the Court found that when Walker stored junk cars on Murphree's land, occasionally parked two eighteen-wheelers on Murphree's land, and mowed the same property — Walker had failed to prove that he had come to adversely possess the land because Murphree had not been put on notice by such acts. However, the Court found that when Walker put homes on Murphree's property, that Walker's action constituted "notice of such kind and quality that it placed Murphree on notice of Walker's claim to the property, and Murphree took action."

Id. A finding that the proof was sufficient to sustain a claim of adverse possession is a fact-finding that requires our application of the substantial evidence/manifest error test. Walker v. Murphree, 722 So.2d 1277, 1280 (¶ 15) (Miss. 1998). If substantial evidence supports the chancellor's fact-findings, this Court must affirm, even though we "might have found otherwise as an original matter." Nichols, 883 So.2d at 556 (¶ 7). And, where the chancellor has failed to make specific findings, we will assume that the chancellor resolved such issue in favor of the appellee.

The Rice court adopted a six-part test for determining whether adverse possession has occurred, and that test has been applied by this Court as follows: "for possession to be adverse it must be (1) under claim of ownership; (2) actual or hostile; (3) open, notorious, and visible; (4) continuous and uninterrupted for a period of ten years; (5) exclusive; and (6) peaceful." Walker v. Murphree, 722 So.2d 1277, 1281 (¶ 16) (Miss.Ct.App. 1998) (citing Rice, 611 So.2d at 871). "Ten years' actual possession by any person claiming to be the owner for that time of any land, uninterruptedly continued for ten years by occupancy, descent, conveyance, or otherwise, in whatever way such occupancy may have been commenced or continued, shall vest in every actual occupant or possessor of such land a full and complete title. . . ."

In Stewart v. Graber , 760 So. 2d 868, 869 (¶¶8-9) (Miss. Ct. App. 2000), the Stewarts merely used land occasionally to pasture cattle without an enclosure and at times gardened. In Walker v. Murphree , 722 So. 2d 1277 (Miss. Ct. App. 1998), looking at the quality rather than the quantity of the possessory acts, the supreme court held, among other things, that Walker's claim of adverse possession failed because he could not provide any details regarding the size of the alleged garden he claimed to have maintained, he never claimed ownership until suit was brought, and he did not counterclaim for title. Id . at 1282 (¶19).

Orcutt v. Chambliss , 243 So. 3d 757, 762 (¶16) (Miss. Ct. App. 2018) (citing Walker v. Murphree , 722 So. 2d 1277, 1280 (¶15) (Miss. Ct. App. 1998) ). "If substantial evidence supports the chancellor's fact-findings, this Court must affirm, even though we ‘might have found otherwise as an original matter.’ " Id. (quoting Nichols v. Funderburk , 883 So. 2d 554, 556 (¶7) (Miss.

Our caselaw recognizes that "[a]dverse possession of ‘wild’ or unimproved lands may be established by evidence of acts that would be wholly insufficient in the case of improved or developed lands." Walker v. Murphree , 722 So. 2d 1277, 1281 (¶16) (Miss. Ct. App. 1998) (quoting Johnson v. Black , 469 So. 2d 88, 90 (Miss. 1985) ). This does not mean, however, that the standard of proof required to show adverse possession is somehow diminished in such a case.