Ark. Code Ann. » Title 26 Chapter 37
Arkansas Code Annotated

Ark. Code Ann. § 26-37-203 (2026)

Conveyance to purchaser — Contest

✓ current as of May 2026
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History. Acts 1983, No. 626, § 4; A.S.A. 1947, § 84-1129; Acts 1987, No. 814, § 5; 1989, No. 938, § 1; 1993, No. 791, § 4; 2003, No. 1215, § 1; 2005, No. 1231, § 4; 2007, No. 1036, § 3; 2011, No. 862, § 2; 2013, No. 1135, § 5; 2013, No. 1231, § 4; 2015, No. 1226, § 1.

Amendments. The 2011 amendment, in (a), inserted “under § 26-37-202” and substituted “convey the tax-delinquent land by issuing” for “issue”; in (b)(2), substituted “one-year period under subdivision (b)(1) of this section” for “two-year period” and inserted “during time of war” and “United States”; and deleted ”if prior to the issuance of the deed the Commissioner of State Lands complied with the laws governing the disposition of tax-delinquent land” at the end of (c).

The 2013 amendment by No. 1135 added “active duty with” preceding “the United States”, and made stylistic changes in (b)(2); and added “tax-delinquent” preceding “land” in (b)(3).

The 2013 amendment by No. 1231 substituted “sold” for “not redeemed within the thirty day period under § 26-27-202” in (a); in (b)(1), substituted “subdivision (b)(2)” for “subdivisions (b)(2) and (3)” and “ninety (90) days” for “one (1) year” and inserted “or a negotiated sale under § 26-37-101” before “is barred”; and deleted (b)(3).

The 2015 amendment substituted “ninety-day” for “one-year” in (b)(2) and made stylistic changes.

Research References

U. Ark. Little Rock L. Rev.

Survey — Property, 10 U. Ark. Little Rock L.J. 605.

Survey of Legislation, 2003 Arkansas General Assembly, Taxation, Tax Forfeited Land Redemption, 26 U. Ark. Little Rock L. Rev. 497.

Case Notes

Statute of Limitations.

Since 50 U.S.C. § 525 (now codified at 50 U.S.C. § 3936) tolled the statute of limitations for the time within which a husband and wife had to bring an action to set aside a default judgment that quieted title in favor of a purchaser who bought the husband and wife's property at a tax sale, the trial court erred in denying a motion to set aside the default judgment where the action was filed within two years of husband's retirement from the military, as required by this section. Small v. Kulesa, 90 Ark. App. 108, 204 S.W.3d 99, cert. denied, 546 U.S. 938, 126 S. Ct. 427, 163 L. Ed. 2d 325 (2005).

Incapacitated sisters could not tack their disability onto their brother's disability for the purpose of extending the redemption period after the brother's land was certified to the State Land Commissioner for failure to pay taxes; rather, the sisters had the right to redeem the land within two years after the brother's disability was removed by death. Givens v. Haybar, Inc., 95 Ark. App. 164, 234 S.W.3d 896 (2006).

Debtor who claimed an equitable interest in the property based on an alleged oral rent-to purchase agreement with the owner could challenge the tax sale and transfer of property to the subsequent purchaser because the state did not file an action in Chancery Court under § 26-38-206, to bar any subsequent claims. Further, § 26-37-203 gave the debtor two years to contest the validity of the conveyance. In re Paro, 362 B.R. 419 (Bankr. E.D. Ark. 2007) (decided under former version of statute).

Cited: Bill's Printing, Inc. v. Carder, 82 Ark. App. 466, 120 S.W.3d 611 (2003).

Notes of Decisions
Cited in 7 cases (2 in the last 5 years), 2003–2026 · leading case: Bill's Printing, Inc. v. Carder, 161 S.W.3d 803 (Ark. 2004).
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Bill's Printing, Inc. v. Carder, 161 S.W.3d 803 (Ark. 2004). · cites it 12× “Ark.Code Ann. § 26-37-203 (Repl.1997). In my view, the Scholeses were deprived of their statutory right to contest the Land Commissioner's limited-warranty deed to the Carders in court because the Land Commissioner, convinced that the Scholeses were correct, exercised his…”
Givens v. Haybar, Inc., 234 S.W.3d 896 (Ark. Ct. App. 2006). · cites it 16× “Ark. Code Ann. §§ 26-37-203 (a) and -202(e).”
Morris v. Landnpulaski, LLC, 309 S.W.3d 212 (Ark. Ct. App. 2009). · cites it 2× “1997) (providing that a property owner has thirty days after a tax sale to redeem his property); Ark.Code Ann. § 26-37-203(b)(l) (Repl.1997) (providing that there is a two-year litigation period in which a conveyance of tax-delinquent property may be contested); Ark.”
Bill's Printing, Inc. v. Carder, 120 S.W.3d 611 (Ark. Ct. App. 2003). · cites it 2× “1996); that because more than thirty days had passed since the sale of the property without redemption as contemplated by the provisions of Ark. Code Ann. § 26-37-203 (a) (Repl. 1997), the Commissioner acted contrary to law in unilaterally canceling the limited warranty deed…”
Small v. Kulesa, 204 S.W.3d 99 (Ark. Ct. App. 2005). · cites it 2× “See Ark. Code Ann. § 26-37-203 (b) (Supp. 2003).”
Tommy Land,in His Capacity as Comm'r of State Lands for the State of Arkansas v. Bas, LLC; Parcel Strategies, LLC; & Banyan Capital Investments, LLC, 2025 Ark. 107, 713 S.W.3d 1. · cites it 2× “See Ark. Code Ann. § 26-37-203 (in general, “an action to contest the validity of a [tax delinquency sale]” must be “commenced within ninety (90) days after the date of conveyance”).”
Lang Props., LLC v. Michael Grober, His Heirs & Assigns; the City of Fort Smith, Arkansas; Sebastian Cnty., Arkansas; & Any Person, Entity or Org. Claiming Any Right, Title, Interest or Ownership in the Real Prop. Located at Section 33, Twp. 08n, Range 32w, Acreage 0, Lot 152, Southbrook Addition to the City of Fort Smith, Arkansas, 2026 Ark. App. 281. · cites it 2× “; see also Ark. Code Ann. § 26-37-203 . The regulatory framework governing such sales likewise advises purchasers that it is their responsibility to conduct their own investigation of title and existing claims before purchase.”
Ark. Code Ann. § 26-37-203(a): 1 case
Givens v. Haybar, Inc., 234 S.W.3d 896 (Ark. Ct. App. 2006). “Ark. Code Ann. §§ 26-37-203 (a) and -202(e).”
Ark. Code Ann. § 26-37-203(b): 1 case
Givens v. Haybar, Inc., 234 S.W.3d 896 (Ark. Ct. App. 2006). “Ark. Code Ann. §§ 26-37-203 (a) and -202(e).”
Ark. Code Ann. § 26-37-203(b)(1): 1 case
Givens v. Haybar, Inc., 234 S.W.3d 896 (Ark. Ct. App. 2006). “Ark. Code Ann. §§ 26-37-203 (a) and -202(e).”
Ark. Code Ann. § 26-37-203(b)(l): 1 case
Morris v. Landnpulaski, LLC, 309 S.W.3d 212 (Ark. Ct. App. 2009). “1997) (providing that a property owner has thirty days after a tax sale to redeem his property); Ark.Code Ann. § 26-37-203(b)(l) (Repl.1997) (providing that there is a two-year litigation period in which a conveyance of tax-delinquent property may be contested); Ark.”
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