Spickler v. Ginn, 2012 ME 46 (Maine Sup. Jud. Ct. 2012)

(quiet title action to settle dispute regarding land conveyed to two different parties; first grantee did not record her deed after property conveyance until 1986; second grantees from same grantor recorded their deed in 1984; trial court jury found second grantee had actual notice of conveyance to first grantee; subsequent conveyances by second grantees to related parties were also found to have had notice of first grantee's interest; first grantee deemed owner of property; second grantee appealed only the legal conclusion from the jury's factual findings; appellate court clarified Maine's statute as "race-notice", meaning subsequent grantees who record their deed first can beat earlier grantees so long as the subsequent grantees had no actual notice of the earlier grantee's interest; based on jury findings of fact establishing second grantees all had notice of first grantee's interest prior to first grantee's recordation of property deed, court affirmed and vested title in first grantee).