Ariz. Rev. Stat. » Title 33
Arizona Revised Statutes

Ariz. Rev. Stat. § 33-324 (2026)

Denial of landlord's title by lessee in possession prohibited

✓ current as of May 2026
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When a person enters into possession of real property under a lease, he may not, while in possession, deny the title of his landlord in an action brought upon the lease by the landlord or a person claiming under him.

Notes of Decisions
Cited in 4 cases, 1969–2016 · leading case: Lewis v. Pleasant Country, Ltd., 840 P.2d 1051 (Ariz. Ct. App. 1992).
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Lewis v. Pleasant Country, Ltd., 840 P.2d 1051 (Ariz. Ct. App. 1992). · cites it 8× “2d 630, 633 (1939), and A.R.S. § 33-324, a tenant cannot claim adverse possession against its landlord.”
Bowen v. Sil-Flo Corp., 451 P.2d 626 (Ariz. Ct. App. 1969). · cites it 4× “Our interpretation of the supplemental agreement answers Bowen’s contention that Sil-Flo is estopped under A.R.S. § 33-324 8 from questioning his title to the area within the placer claims.”
Blackhawk v. McComb (Ariz. Ct. App. 2016). · cites it 4× “A.R.S. § 33-324. McComb, however, did not take possession as a tenant under a lease; she took possession under a warranty deed as a result of a contract of sale.”
Heuschkel v. Bergmann (Ariz. Ct. App. 2015). · cites it 2× “2d 630, 633 (1939); see also A.R.S. § 33-324. When, however, there is no landlord-tenant relationship, the rule barring a tenant from bringing an adverse possession claim does not apply.”
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