First Properties, LLC v. JPMorgan Chase Bank

A Jefferson County fire district foreclosed on Ruthia Dumas's property for unpaid fire-protection fees and recorded a deed listing itself as both grantor and grantee, without identifying Dumas as the prior owner of record. Dumas continued living on the property and obtained a mortgage on it the following year, which was later assigned to JPMorgan Chase Bank (plaintiff). Years later, the fire district sold the property by quitclaim deed to First Properties, LLC (defendant), and that later deed did correctly list Dumas as the prior owner. JPMorgan sued for a declaratory judgment that it was a bona fide purchaser for value, since it had no notice of the fire district's or First Properties's claims to the property; the trial court agreed, and First Properties appealed.

Whether a deed lying outside a property's chain of title, even if recorded, gives a subsequent purchaser constructive notice of the interest claimed in that deed.