Pioneer Builders Co. of Nevada v. K D A Corp., 2012 UT 74

Pioneer financed the purchase of Sunrise Village RV Park, which included four parcels with both recorded and unrecorded leases.
Pioneer recorded its Original Deeds for Parcels 36, 37, and 38 on November 17, 2000; Parcel 25 was not included.
Modification Deeds in August 2001 attempted to convey Parcel 25 to Pioneer, but Pine Ridge lacked title to Parcel 25 at that time (wild deed).
Nalder Affidavit (September 2002) attempted to retroactively include Parcel 25 in the conveyance; Parcel 25 was later quitclaimed to Pine Ridge (March 9, 2005).
Appraisal Report (December 29, 2000) described 28 leases and included a Site Map; there is dispute whether Pioneer received the full report.
District court granted partial summary judgment to Pioneer but held Defendants superior on remaining issues; court later remanded for factual determinations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Constructive notice standard	Pioneer contends district court misapplied notice standard by mixing recorded with unrecorded leases.	Defendants contend Pioneer had constructive notice of unrecorded leases through observed use and documents.	Reversed; district court erred and remanded for proper standard.
Parcel 25 title and notice	Modification Deeds and Nalder Affidavit should cure title and give Pioneer priority.	Modification Deeds were wild and did not impart notice; after-acquired title retroactively validates but cannot defeat prior recordation.	Parcel 25 interests depend on timing of recordings; remanded for determinations.
After-acquired title effect on priority	After-acquired title retroactively validates Pioneer’s interest to prevail.	Retroactive validation should not defeat third-party record interests that occurred before validation.	Retroactive validation does not trump pre-existing recorded interests; remanded.
Executory contracts (Payment Defendants)	Payment Defendants' incomplete payments affect their ownership interest and priority.	Executory contract status does not defeat already acquired rights or priority.	Contract status does not affect priority; Defendants’ interests valid.
Insurance reference prejudice	Insurance references influenced district court’s reasoning and prejudiced Pioneer.	Insurance discussion was immaterial and not prejudicial.	No reversal for insurance references; no demonstrated prejudice.

Arnold Indus., Inc. v. Love, 63 P.3d 721 (Utah 2002) (two-step inquiry notice analysis; open-easement scenario)
First Am. Title Ins. Co. v. J.B. Ranch, Inc., 966 P.2d 834 (Utah 1998) (good-faith purchaser required; record notice principles)
Stumph v. Church, 740 P.2d 820 (Utah Ct. App. 1987) (observation of tenants and lack of duty to inquire discussed)
Haik v. Sandy City, 254 P.3d 171 (Utah 2011) (to be in good faith, purchaser must have no notice of prior unrecorded interest)
FDIC v. Taylor, 267 P.3d 949 (Utah Ct. App. 2011) (after-acquired title doctrine analyzed in race-notice context)