Anthony sold a 160-acre tract of land to Melissa in 1983. In the deed of conveyance, Anthony reserved all subsurface rights to oil, gas, and minerals. Since then, Melissa has maintained a single-family residence on the property and has farmed the 159 acres not immediately surrounding the house. This year Melissa contracted to sell the property to Frank for $600,000. The contract is silent on the matter of marketability of title but calls for Melissa to convey the property in fee simple absolute. At closing she presented Frank with such a deed, making no exceptions for any oil, gas, or mineral rights. At Closing Frank's lawyer, Lisa, gives an attorney's opinion wherein she objects to the marketability of the title because she examined title and found the reservation of rights in Anthony. Melissa response by asserting that she acquired full marketable title by virtue of adverse possession. Generally, adverse possession law does not treat farming as adverse to mineral development because farming does not physically interfere with any minerals that may lie below the surface or prevent Anthony from entering the surface at some time in the future. Is Lisa, Frank's attorney's, objection to a lack of marketable title valid, given that Melissa is presenting a fee simple absolute deed?