Utah Code » Title 57, Chapter 1 — Conveyances
Utah Code

Utah Code § 57-1-10 (2026)

After-acquired title passes

✓ laws through the 2026 General Session (checked Sept. 2026)
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If any person conveys any real estate by conveyance purporting to convey the real estate in fee simple absolute, and at the time of the conveyance the person does not have the legal estate in the real estate, but afterwards acquires the legal estate:
the legal estate subsequently acquired immediately passes to the grantee, the grantee's heirs, successors, or assigns; and
the conveyance is as valid as if the legal estate had been in the grantor at the time of the conveyance.
Subsection (1) does not apply to a conveyance by quitclaim deed.

Amended by Chapter 287, 2007 General Session

Notes of Decisions
Cited in 9 cases, 1983–2013 · leading case: Arnold Indus., Inc. v. Love, 2002 UT 133, 63 P.3d 721.
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Arnold Indus., Inc. v. Love, 2002 UT 133, 63 P.3d 721. · cites it 10× “Utah Code Ann. § 57-1-10 (2000); 2 see also Barlow Soc’y v.”
Pioneer Builders Co. of Nevada v. K D A Corp., 2012 UT 74, 292 P.3d 672. · cites it 9× “See Utah Code § 57-1-10(1). . See id. § 57-1-10(1)(b).”
Fed. Deposit Ins. Corp.v. Taylor, 2011 UT App 416, 267 P.3d 949. · cites it 10× “Utah Code Ann. § 57-1-10 (1)(a)-(b). Pursuant to the statute, "a conveyance made by grantor not holding fee title to property is binding when the grantor later obtains fee title.”
Spears v. Warr, 2002 UT 24, 44 P.3d 742. · cites it 2× “More importantly, the trial judge found that "the Warranty Deeds ... were not intended to be a complete integration of the parties' understanding.”
Haslem v. Ottosen, 689 P.2d 27 (Utah 1984). · cites it 2× “, 1953, § 57-1-10. Defendants counterclaimed, pleaded the statute of limitations (U.”
Barlow Soc'y v. Com. Sec. Bank, 723 P.2d 398 (Utah 1986). “, 1953, § 57-1-10. The antecedent quitclaim deed to plaintiff on the other hand could not and did not divest Barlow of his subsequent fee simple absolute title to the south portion after reconveyance from Ballard and Midg-ley.”
Hall v. Fitzgerald, 671 P.2d 224 (Utah 1983). “, 1953, § 57-1-10; Cox v. Ney, Utah, 580 P.2d 1085 (1978), as well as the related doctrine of estoppel by deed.”
Utah Farm Prod. Credit Ass'n v. Wasatch Bank of Pleasant Grove, 734 P.2d 904 (Utah 1987). “72-acre parcel until 1979, Hansens in effect assigned no more than their equitable rights under the con *906 tract of sale between Koyle and Bo-ley/Hansen, and the fee simple title Han-sens acquired in the 16.”
Ashworth v. Bullock, 2013 UT App 96, 304 P.3d 74. · cites it 2× “See generally Utah Code Ann. § 57-1-10 (LexisNexis 2010).”
Utah Code § 57-1-10(1): 1 case
Pioneer Builders Co. of Nevada v. K D A Corp., 2012 UT 74, 292 P.3d 672. “See Utah Code § 57-1-10(1). . See id. § 57-1-10(1)(b).”
Utah Code § 57-1-10(1)(a): 2 cases
Pioneer Builders Co. of Nevada v. K D A Corp., 2012 UT 74, 292 P.3d 672. “See Utah Code § 57-1-10(1). . See id. § 57-1-10(1)(b).”
Fed. Deposit Ins. Corp.v. Taylor, 2011 UT App 416, 267 P.3d 949. “Utah Code Ann. § 57-1-10 (1)(a)-(b). Pursuant to the statute, "a conveyance made by grantor not holding fee title to property is binding when the grantor later obtains fee title.”
Utah Code § 57-1-10(1)(b): 1 case
Pioneer Builders Co. of Nevada v. K D A Corp., 2012 UT 74, 292 P.3d 672. “See Utah Code § 57-1-10(1). . See id. § 57-1-10(1)(b).”
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