Arizona Revised Statutes
Ariz. Rev. Stat. § 42-18206 (2026)
Redemption during pendency of action to foreclose
✓ current as of May 2026
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42-18206. Redemption during pendency of action to foreclose
Any person who is entitled to redeem under article 4 of this chapter may redeem at any time before judgment is entered, notwithstanding that an action to foreclose has been commenced, but if the person redeems after a notice is recorded pursuant to section 12-1191, judgment shall be entered in favor of the plaintiff against the person for the costs incurred by the plaintiff, including all of the following:
1. The cost of a litigation guarantee or other insured title report.
2. The cost of identifying interests of record.
3. Reasonable attorney fees to be determined by the court.
Notes of Decisions
Cited in 16
cases (6 in the last 5 years), 1999–2026 · leading case: Leveraged Land Co., LLC v. Hodges, 232 P.3d 756 (Ariz. Ct. App. 2010).
Leveraged Land Co., LLC v. Hodges, 232 P.3d 756 (Ariz. Ct. App. 2010). “The court granted the motion, rejecting arguments by Raven and Bingham that they were bona fide purchasers of the land.”
Ritchie v. Salvatore Gatto Partners, L.P., 222 P.3d 920 (Ariz. Ct. App. 2010). “A.R.S. § 42-18206. FACTS AND PROCEDURAL HISTORY ¶ 3 Appellee owned a tax lien certificate of purchase on property located in Mohave County and owned by Vanetta Jean Geyer.”
Fisher v. Edgerton, 336 P.3d 167 (Ariz. Ct. App. 2014). “”), 12-1364 (2003) (“[T]he court shall award the successful party reasonable attorney fees____”), 41-1491.”
Leveraged Land Co., LLC v. Hodges, 249 P.3d 341 (Ariz. 2011). “See A.R.S. § 42-18206 (if owner redeems, judgment shall be entered in favor of lien purchaser).”
Friedemann v. Kirk, 5 P.3d 950 (Ariz. Ct. App. 2000). “¶ 8 In contrast to § 42-18152, A.R.S. § 42-18206 allows redemption during pendency of an action to foreclose “at any time before judgment is entered.”
PLM Tax Certificate Prog. 1991-92 v. Denton Investments, Inc., 986 P.2d 243 (Ariz. Ct. App. 1999). “…since been repealed, see 1997 Ariz. Sess. Laws 150 , section 9, effective January 1, 1999, and replaced with A.R.S. section 42-18206 (1999).”
Tfltc LLC v. Beth Ford, 514 P.3d 913 (Ariz. 2022). “TFLTC then sought to recover attorney fees and costs in each case pursuant to A.R.S. § 42-18206, including fees and costs incurred after the certificates of redemption had issued.”
Porthos v. Pulito (Ariz. Ct. App. 2018). “Here, Porthos made a prima facie showing that it was entitled to judgment under A.R.S. § 42-18206 as a matter of law—it showed that it held the tax lien on Pulito’s property and that Pulito redeemed the property before judgment was entered.”
Tax Lein v. Beitman (Ariz. Ct. App. 2024). “at 305 , ¶ 2 (quoting A.R.S. § 42-18206). FACTUAL AND PROCEDURAL HISTORY ¶3 Except as noted, the parties do not dispute the relevant facts.”
Arizona Bright v. McDougall (Ariz. Ct. App. 2026). “¶7 The court denied the motion, stating it was aware of the redemption at the time of the hearing, accordingly "[t]his is why the [c]ourt did not order the property to [Arizona Bright], but instead ordered the requisite [f]ees and costs allowed under A.R.S. § 42-18206." ¶8…”
Roff v. Grant/j & J (Ariz. Ct. App. 2026). “¶20 Under A.R.S. § 42-18206, the owner of property may “redeem at any time before judgment is entered, notwithstanding that an action to foreclose has been commenced.”
Advanced Prop. Tax Liens, Inc. v. Jorge Othon (Ariz. Ct. App. 2021). “” In particular, APTL argues that Othon “has been unjustly enriched by owning the Property but never redeeming the taxes” owed on it—which APTL paid—“or paying [APTL’s] fees and costs pursuant to A.R.S. § 42-18206.” This argument ignores the content and actual result of the…”
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