Gates v. Sprint Spectrum, L.P., 349 Fed. Appx. 257 (10th Cir. 2009)

(defendant's placement of cell phone antenna on electricity transmission tower located on plaintiff's property constituted (under Texas law) permanent rather than temporary trespass because neither existence nor nature of nuisance changed over time; result is that any alleged injury occurred before plaintiff acquired real estate at issue and any cause of action vested in property owner at time of injury; thus, plaintiff lacked standing to sue).