What is the test for constructive possession of land?

MultiRegion, United States of America

The following excerpt is from Pacific Coal & Transportation Co. v. Pioneer Mining Co., 205 F. 577 (9th Cir. 1913):

'The constructive possession of land is always in the holder of the best title, unless he has renounced it; and this constructive possession can never be ousted by anything less than an actual possession maintained for the necessary period.' 1 Cyc. 982.

Says the court in Bliss v. Johnson et al., 94 N.Y. 235, 242:

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