Updated on November 14, 2025

Property disputes in Los Angeles can be stressful, especially when chain of title, deed transfers, or ownership records are unclear or challenged. Working with an experienced Los Angeles quiet title litigation attorneys ensures your property rights are protected and your real property title remains free from encumbrances, clouds, or adverse claims.

Our team at Schorr Law specializes in quiet title actions, helping Los Angeles residential homeowners, commercial investors, and real estate developers resolve complex real estate disputes involving recorded deeds, property boundaries, easements, and undisclosed liens efficiently and effectively.

Key Takeaways

  • Quiet title disputes in Los Angeles often arise from unclear chain of title, deed transfers, or ownership claims.
  • Muktarian v. Barmby confirms the statute of limitations does not run while a property owner remains in possession.
  • If you’re in possession, you may bring a quiet title action without a time limit under California law.
  • The statute only activates when an adverse party asserts a hostile claim while you’re out of possession.
  • Strong documentation—including deeds, tax records, and title reports—is key to protecting ownership.
  • A Los Angeles quiet title attorney can investigate title records, remove title defects, and defend ownership in court.
  • Courts statewide still cite Muktarian to determine if a quiet title case is timely and legally valid.
  • Immediate legal action protects your real estate title from encumbrances, fraud, or co-ownership disputes.

What Is the Significance of the Muktarian v. Barmby Case for California Property Owners?

One of the most influential cases impacting California’s quiet title law is Muktarian v. Barmby, 63 Cal.2d 558 (1965). This landmark decision did a deep dive into the statute of limitations for quiet title actions, a crucial concept for property owners throughout California.

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In Muktarian v. Barmby, the plaintiff sought to quiet title to real property against a relative who claimed ownership through an earlier deed. The defendant argued that the claim was barred by the statute of limitations.

The California Supreme Court, however, held that the statute of limitations does not begin to run against a property owner in possession.  The reasoning from the case is that an owner in possession essentially has no reason to go pick a fight with other claimants to disprove any interest they may have while the owner is still in possession.   Of course, every case requires a case by case analysis of the statute of limitations but this case certainly helps guide the analysis.


The Muktarian v. Barmby decision remains one of the most frequently cited cases in California real estate law because it established clear rules for timing and ownership protection. A Los Angeles quiet title actions lawyer can help you understand and apply these principles to your specific property situation.

Here’s what every Los Angeles property owner should know:

  • Understand your right to sue: If you are in legal possession of the property, you generally have no time limit to bring a quiet title claim.  But, let us help you figure out if this applies to your situation.

  • Recognize adverse claims: The statute of limitations begins only when another party makes a clear, hostile or conflicting ownership claim to your property while you are out of possession.

  • Maintain strong documentation: Keep deeds, tax records, and title reports up to date to strengthen your ownership claim.

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For more detailed legal guidance, see the California Code of Civil Procedure §760.010, which governs quiet title actions statewide.


Why Should You Hire a Quiet Title Action Attorney in Los Angeles?

Hiring a qualified Los Angeles quiet title actions attorney ensures that your property interests are protected throughout every stage of a title dispute. A skilled attorney can assist with:

  • Title Chain Investigation: Investigate property title records and uncover hidden liens or improper transfers that may affect ownership.

  • Legal Filings: File quiet title complaints, lis pendens and other necessary court documents to remove clouds or defects on title.

  • Ownership Defense: Defend your ownership rights against adverse possession claims or fraudulent conveyance cases, or disputes involving co-owners and heirs.

  • Litigation and Negotiation: Represent you in mediation, settlement negotiations or court proceedings involving residential, commercial, or vacant land.

Learn more about how our law firm can assist by visiting our Los Angeles office or by calling (866) 718-4240 to speak with a Los Angeles Quiet Title Actions Lawyer today.


How Does Muktarian v. Barmby Still Impact Quiet Title Cases in California Today?

More than half a century later, Muktarian v. Barmby continues to shape modern California real estate law. Courts across the state, including in Los Angeles County, regularly cite it when deciding whether a quiet title action is timely filed.

This case protects real property owners from losing their rights simply because time has passed, as long as they remain in possession of the property. For homeowners and real estate investors that means your ownership claim rights remain secure even if disputes arise years after the original purchase, transfer of deed, or recording of title documents.

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How Can You Protect Your Property Ownership Rights in Los Angeles?

The landmark case Muktarian v. Barmby case serves as a reminder that California law strongly favors lawful property owners. If your real estate title in Los Angeles County is being disputed or challenged—whether through a recorded deed, unresolved lien, or ownership claim by a third party—it is critical to take immediate legal action. Delays can complicate your case and increase risk exposure.

Contact an experienced Los Angeles quiet title attorney at Schorr Law today to review your title, clear encumbrances, and protect your real estate investment through strategic litigation or negotiated resolution.

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