In SW Baseline v. Augusta Ranch, the Arizona Court of Appeals held that an entity which sues for damages for a violation of the false document recording statute, ARS 33-420, must own the property affected by the false document, on the date of the recording. The Court of Appeals went on to rule that a quit claim deed may not, by its nature, give rise to a claim of a false recording as it only purports to convey whatever interest the grantor “may have”. In and of itself, a quitclaim deed does not, necessarily, assert that the grantor of the quitclaim deed actually has any interest in the subject real property. The Court of Appeals did not entirely rule out the possibility of finding liability for the recording of a quitclaim deed. Imagine if a ne’er-do-well thought he could record a quitclaim deed to your house to some third party, with impunity. If he can defend what is otherwise a misdemeanor just by saying ‘I wasn’t claiming I owned the property, I was just giving whatever interest I might have to Charlie’, the opportunities for mischief are profound.