Arizona Revised Statutes
Ariz. Rev. Stat. § 12-525 (2026)
Real property in adverse possession and use under duly recorded deed with possessor paying taxes; five year limitation; exception
✓ current as of May 2026
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A. An action to recover real property from a person in peaceable and adverse possession, and cultivating, using or enjoying the property, and paying taxes thereon, and claiming under a deed or deeds duly recorded, shall be commenced within five years after the cause of action accrues, and not afterward.
B. This section shall not apply to anyone in possession of land, who in the absence of this section would claim title through a forged deed, and no one claiming under a forged deed or a deed executed under a forged power of attorney shall be allowed the benefits of this section.
Notes of Decisions
Cited in 7
cases (2 in the last 5 years), 1967–2025 · leading case: Nicholas v. Giles, 426 P.2d 398 (Ariz. 1967).
Nicholas v. Giles, 426 P.2d 398 (Ariz. 1967). “” A.R.S. § 12-525 provides: “A. An action to recover real property from a person in peaceable and adverse possession, and cultivating, using or enjoying the property, and paying taxes thereon, and claiming under a deed or deeds duly recorded, shall be commenced within five years…”
Dominguez v. Dominguez, 567 P.3d 81 (Ariz. 2025). “To emphasize the point, the legislature provided that “no one claiming under a forged deed or a deed executed under a forged power of attorney shall be allowed the benefits of [§ 12-525].” Id. ¶19 Consequently, § 12-525 necessarily reflects the legislature’s view that subsection…”
River Farms, Inc. v. Fountain, 520 P.2d 1181 (Ariz. Ct. App. 1974). “Although no specific adverse possession statute is mentioned in the conclusions of law we find the most applicable statute to be A.R.S. § 12-525: “§ 12-525. Real property in adverse possession and use under duly recorded deed with possessor paying taxes;- five year limitation;…”
Bowen v. Sil-Flo Corp., 451 P.2d 626 (Ariz. Ct. App. 1969). “By upholding the judgment of the trial court in this regard, we find it unnecessary to determine (1) whether Sil-Flo has a vested possessory right to its two claims under the doctrine of adverse pos *277 session, see 30 U.”
Blackhawk v. McComb (Ariz. Ct. App. 2016). “¶9 The superior court found McComb adversely possessed the Property under A.R.S. § 12-525, which provides: An action to recover real property from a person in peaceable and adverse possession, and cultivating, using or enjoying the property, and paying taxes thereon, and…”
Triyar v. Rem (Ariz. Ct. App. 2017). “It also asserted A.R.S. §§ 12-525(a) (2017) and 12-526(a) (2017) (five- and ten-year limits for actions to recover real property in adverse possession).”
Roman Jr. v. Nationstar (Ariz. Ct. App. 2022). “§ 12-548(A)(1); a tort claim related to trespass within two years, § 12-542(3); and a claim for recovery of real property within five years, § 12-525(A). Each time limitation is measured from when the cause of action accrues.”
— Ariz. Rev. Stat. § 12-525(A) — 2 cases
Dominguez v. Dominguez, 567 P.3d 81 (Ariz. 2025). “To emphasize the point, the legislature provided that “no one claiming under a forged deed or a deed executed under a forged power of attorney shall be allowed the benefits of [§ 12-525].” Id. ¶19 Consequently, § 12-525 necessarily reflects the legislature’s view that subsection…”
Roman Jr. v. Nationstar (Ariz. Ct. App. 2022). “§ 12-548(A)(1); a tort claim related to trespass within two years, § 12-542(3); and a claim for recovery of real property within five years, § 12-525(A). Each time limitation is measured from when the cause of action accrues.”
— Ariz. Rev. Stat. § 12-525(B) — 1 case
Dominguez v. Dominguez, 567 P.3d 81 (Ariz. 2025). “To emphasize the point, the legislature provided that “no one claiming under a forged deed or a deed executed under a forged power of attorney shall be allowed the benefits of [§ 12-525].” Id. ¶19 Consequently, § 12-525 necessarily reflects the legislature’s view that subsection…”
— Ariz. Rev. Stat. § 12-525(a) — 1 case
Triyar v. Rem (Ariz. Ct. App. 2017). “It also asserted A.R.S. §§ 12-525(a) (2017) and 12-526(a) (2017) (five- and ten-year limits for actions to recover real property in adverse possession).”
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