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Litigating Quiet Title Actions: Key Considerations and Strategies to Navigate a Complex Process

Preliminary Investigation; Naming All Possible Defendants; Unique Procedural Issues; Counterclaims and Defenses

Recording of a 90-minute premium CLE video webinar with Q&A

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Conducted on Thursday, February 8, 2024

Recorded event now available

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This CLE webinar will guide counsel for all parties to a quiet title action through the complex process, providing practical instruction and litigation strategies. The panel will discuss how to determine when a quiet title action is necessary. The panel will also address the investigation process to be taken before filing an action so that the plaintiff may satisfy their burden of proof and all necessary defendants to the action are named and properly served, as well as describe unique procedural considerations.


Understanding quiet title actions can be crucial when disputes arise over property ownership during real estate transactions. Often considered a last resort, these actions may be necessary where there are competing claims to property, unclear ownership records, or potential title defects.

Issues litigated in quiet title actions are numerous and complex and can involve multiple parties with an interest in the property in question including anyone and everyone who may claim an ownership interest in the subject property. Therefore, counsel on both sides of the action should clearly understand litigation strategies and considerations unique to these claims.

For example, counsel should understand the preliminary investigation required before filing a quiet title action; how to ensure all possible defendants are named and properly served; unique procedural issues; possible defenses and counterclaims; and what can be expected after a judgment is rendered.

Listen as our expert panel guides practitioners through the process of litigating a quiet title action with practical instruction and litigation strategies for counsel representing all parties to the action.



  1. Introduction: when is a quiet title action the best option?
  2. Grounds for a quiet title action
  3. Preparation and investigation
    1. State/local considerations
    2. Preliminary research and investigation
      1. Identifying all possible defendants
      2. Satisfying the plaintiff's burden of proof
    3. Procedural considerations (e.g., jurisdiction, statute of limitations)
  4. Litigating a quiet title action
    1. Contested vs. uncontested suits
    2. Naming all defendants to the action
    3. Drafting the complaint
    4. Adequate service of process
    5. Notice of pending action--lis pendens
    6. Responding to the complaint--possible counterclaims and defenses
    7. Discovery strategies
    8. Evidentiary considerations
    9. Obtaining final judgment
  5. What to expect after the judgment


The panel will review these and other important considerations:

  • What are the grounds for a quiet title action?
  • What are unique procedural issues to be considered including state/local requirements?
  • How can counsel ensure that all parties who may claim an ownership interest in the property are properly served and notified of the action?
  • What are possible defenses and counterclaims to a quiet title action?
  • What can the parties expect after a judgment is rendered?


Glosser, Lawrence
Lawrence S. (Larry) Glosser

Ahlers Cressman & Sleight

Mr. Glosser’s primary focus is real estate, business, and corporate law.  His practice combines transaction...  |  Read More

Schorr, Zachary
Zachary D. Schorr

Lead Trial Attorney
Schorr Law

Mr. Schorr is an experienced Los Angeles real estate attorney and litigator who enjoys the litigation process and...  |  Read More

Weber, Beverly
Beverly Weber

Armstrong Teasdale

Ms. Weber has nearly 20 years of experience in contentious matters at both the trial and appellate levels in state and...  |  Read More

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