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Cal. Civil Code § 1214 (2026)

✓ current as of May 2026
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Every conveyance of real property or an estate for years therein, other than a lease for a term not exceeding one year, is void as against any subsequent purchaser or mortgagee of the same property, or any part thereof, in good faith and for a valuable consideration, whose conveyance is first duly recorded, and as against any judgment affecting the title, unless the conveyance shall have been duly recorded prior to the record of notice of action.

Notes of Decisions
Cited in 63 cases (5 in the last 5 years), 1944–2025 · leading case: Burkart v. Coleman (In Re Tippett), 542 F.3d 684 (9th Cir. 2008).
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Burkart v. Coleman (In Re Tippett), 542 F.3d 684 (9th Cir. 2008). · cites it 3× “Cal. Civ.Code § 1214. The transfer of the Tip-petts’ residence to the bankruptcy estate was just such an unrecorded conveyance, and is void as to Coleman, a good faith purchaser for value who duly recorded his purchase.”
Gregg v. Cloney, 2001 Cal. Daily Op. Serv. 6925 (Cal. Ct. App. 2001). “) Civil Code section 1214 provides: “Every conveyance of real property or an estate for years therein, other than a lease for a term not exceeding one year, is void as against any subsequent purchaser or mortgagee of the same property, or any part thereof, in good faith and for…”
Deutsche Bank Nat'l Trust Co. v. McGurk, 206 Cal. App. 4th 201 (Cal. Ct. App. 2012). · cites it 2× “) In 1895, Civil Code section 1214 was amended to provide, as it does now, that “[e]very conveyance of real property .”
First Bank v. East West Bank, 199 Cal. App. 4th 1309 (Cal. Ct. App. 2011). “) Stating the rule differently, Civil Code section 1214 reads in relevant part, “Every conveyance of real property .”
Longview Int'l, Inc. v. Stirling, 247 Cal. Rptr. 3d 793 (Cal. Ct. App. 5th 2019). “Catambay makes an alternative argument: that even if the abstract of judgment is retroactively validated, it would not affect her interest in the property because the validation did not occur until the corporation's powers were revived, which was after the date the property was…”
Gates Rubber Co. v. Ulman, 214 Cal. App. 3d 356 (Cal. Ct. App. 1989). “Civil Code section 1214 provides in relevant part: “Every conveyance of real property, other than a lease for a term not exceeding one year, is void as against any subsequent purchaser or mortgagee of the same property, .”
In Re Lester D. Lane & Bonnie F. Lane, Debtors. Hurst Concrete Prods., Inc. v. Lester D. Lane Bonnie F. Lane, 980 F.2d 601 (9th Cir. 1992). “Due to the constructive notice supplied by a lis pendens, a conveyance of the real property to a subsequent bona fide purchaser “is void as against .”
Farmers & Mechanics Sav. Bank v. Garofalo, 595 A.2d 341 (Conn. 1991). “, Cal. Civ. Code § 1214 (Deering 1990); N.Y.”
Stagen v. Stewart-West Coast Title Co., 149 Cal. App. 3d 114 (Cal. Ct. App. 1983). “) *123 A judgment favorable to the plaintiif relates to, and receives its priority from, the date the lis pendens is recorded, and is senior and prior to any interests in the property acquired after that date (Civ.”
40235 Washington St. Corp. v. WC LUSARDI, 177 F. Supp. 2d 1090 (S.D. Cal. 2001). “In 1990, California was a "race-notice” state, see Cal.Civ. Code § 1214, meaning that Lusardi must have purchased his tax deed without knowledge of the bankruptcy petition (the "notice” element) and recorded it before Washington Street recorded a copy or notice of the bankruptcy…”
Davisson v. Engles (In Re Engles), 193 B.R. 23 (Bankr. S.D. Cal. 1996). “Cal.Civ.Code § 1214 (West Supp.1996). The courts reasoned that the debtor could ‘step into the shoes’ of the bankruptcy trustee, who has the status of a hypothetical bona fide purchaser, and avoid the sale under Code section 544.”
Brooks-Hamilton v. City of Oakland (In Re Brooks-Hamilton), 348 B.R. 512 (Bankr. N.D. Cal. 2006). · cites it 2× “2d at 604 -05 (citing Cal. Civ.Code § 1214). Thus, the Trustee’s motion for summary judgment must be denied to the extent it relates to the Lis Pendens.”
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