With no explanation, chose the best option from "A", "B", "C" or "D". owner); Tucker v. Hankey, 173 Kan. 593, 250 P.2d 784, 788 (Kan. 1952) (“To constitute adverse possession of land, it is not absolutely necessary that there should be [enclosure, buildings, or cultivation. ...”). With respect to agricultural lands whose primary purpose is cattle grazing, courts have consistently held that the actual, physical, and hostile possession elements of an adverse possession claim may be satisfied simply upon a showing that the individual who claims to have adversely possessed the land has had his cattle graze on the disputed parcel. See, e.g., Thornburg v. Haecker, 243 Neb. 693, 502 N.W.2d 434, 438 (Neb. 1993); Davis v. Parke, 135 Ore. App. 283, 898 P.2d 804, 806 (Or. Ct. App. 1995); Overson v. Cowley, 136 Ariz. 60, 664 P.2d 210, 217-18 (Ariz. Ct. App. 1982) (<HOLDING>). As the Wyoming Supreme Court, in summarizing

A: holding that the phrase possession or custody in  5225b requires actual and not merely constructive possession
B: holding that a past arrest for possession without more is simply not enough to provide reasonable articulable suspicion that the person is currently in possession
C: holding cattle grazing without more sufficient to establish actual possession element
D: holding that k no wing possession can be demonstrated by proof of either actual or constructive possession
C.