In 1946, Georgia O’Keeffe (plaintiff) noticed that three of her paintings were missing from a gallery, but she did not report the pieces stolen until 1972. In 1975, O’Keeffe learned that her paintings were in a gallery in New York, and in March 1976 she brought suit in replevin against purchaser Barry Snyder (defendant). Snyder impleaded Ulrich Frank, who sold him the paintings. Frank claimed that his father had possession of the paintings for over 30 years. Snyder moved for summary judgment. Snyder asserted that he was a purchaser for value, he had title by adverse possession, and O’Keeffe’s action was barred by the applicable six-year statute of limitations. O’Keeffe filed a cross-motion arguing that the paintings were stolen, she had rightful title, and the statute of limitations had not run. The trial court granted Snyder’s motion, holding that the six-year limitations period for replevin actions started to run at the time of the theft. The appellate court reversed, granting judgment for O’Keeffe on the grounds that (1) the paintings were stolen, (2) the limitations period was the same as the adverse-possession period, and (3) Snyder failed to establish adverse possession (which the appellate court concluded he had the burden to demonstrate). Snyder appealed to the Supreme Court of New Jersey.