A Massachusetts court has held that hiring a landscaper to regularly maintain a strip of land is sufficient to constitute "possession" and can ripen into adverse possession once the statute of limitations runs. Miller v. Abramson, 131 N.E.3 863 (Mass. App. Ct. 2019). This was the case when a line of vegetation formed a natural boundary line sufficient to signal that the adverse possessor claimed the property as their own. This was so even though the line of vegetable was penetrable.