Cecilia M Lewis Et Vir v. Ray C Debord Et Ux, 356 P.3d 314

In 2003 the Lewises obtained a money judgment against the MacKeans and recorded a certified copy in Pima County in 2006 and a renewal in 2008. Neither filing included the separate information statement required by A.R.S. §§ 33-961(C) and 33-967(A).
In 2008 Karen MacKean transferred the property to Sonomex, LLC; in 2012 the Debords purchased the property from Sonomex and recorded fee title.
After the Debords bought the property the Lewises sought to foreclose their judgment lien; the Debords moved for summary judgment saying the lien was invalid because the Lewises failed to file the required information statement.
The superior court granted summary judgment for the Debords; the court of appeals affirmed but held the omission only affected priority as to subsequent purchasers, not validity.
The Arizona Supreme Court granted review to decide (1) whether failure to file the information statement invalidates a recorded lien and (2) whether the priority consequence in § 33-967(D) applies against subsequent purchasers holding fee title.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether failing to attach the § 33-967 information statement to a certified recorded judgment invalidates the judgment lien	Lewis: Recording the certified judgment under § 33-961 creates a valid lien; failure to file the information statement affects only priority, not validity	Debord: Failure to attach the information statement renders the lien invalid as to the property	The court held the lien is valid when the certified judgment is recorded under § 33-961(A); omission of the information statement does not invalidate the lien but affects priority against competing interests
Whether § 33-967(D)’s reference to “priority” deprives a subsequent purchaser of fee title (with record/constructive notice) of taking property subject to an existing judgment recorded without the information statement	Lewis: “Priority” governs ranking among competing creditors (perfection), not the rule that subsequent purchasers with notice take subject to recorded liens	Debord: The information-statement requirement creates a narrow exception: a later purchaser who records fee title before the information statement has priority over the lien	The court held § 33-967(D) addresses priority among creditors (perfection) and does not displace the default rule that a purchaser with constructive or actual notice of a recorded judgment takes subject to the lien

Sysco Ariz., Inc. v. Hoskins, 235 Ariz. 164 (discussing nature and effect of judgment liens)
BMO Harris Bank, N.A. v. Wildwood Creek Ranch, LLC, 236 Ariz. 363 (statutory interpretation de novo; prospective statutory amendment not controlling)
Lewis v. Debord, 236 Ariz. 57 (appellate decision below addressing priority issue)
Collins v. Stockwell, 137 Ariz. 416 (recorded lien gives constructive notice and should alert record-searchers)
Estate of McGill ex rel. McGill v. Albrecht, 203 Ariz. 525 (courts decline to read statutory requirements into a statute when legislature used explicit language elsewhere)
Freeman v. Wintroath Pumps, 13 Ariz. App. 182 (duration and effect of judgment liens)