Holes in the Limitations Period

Be careful, when mustering old authorities regarding limitations periods: they were retroactively tolled during the late unpleasantness.

"[A]t all events, possession has been adverse since the date of the deed, as set forth in the answer, eleventh August, 1855, and more than 20 years have elapsed since then to the date of filing this bill, excluding time from sixth May, 1861, to first January, 1867."

Burns v. Headrick, 85 Tenn. 102, 2 S.W. 259, 261 (1886).