Eighth Circuit -- Sarah Illig v. Union Electric Company

 The statute of limitations for trespass accrues upon the first action that would give a reasonably diligent owner notification of the trespass.  

Company held easement for purpose X, purpose gradually changed to Y, gov't approved use for Y, X abandoned.  Claim accrues with publication of gov't decision.

Repeated intrusions are necessary for continuous trespass - continuing presence of electrical lines insufficient.

Sarah Illig v. Union Electric Company