§ 761.020.Requirements of Complaint

This is the section practitioners and self-represented litigants alike lean on most, because it spells out exactly what a quiet title complaint has to contain. It must be verified, and it must include five things: a description of the property (for real property, both the legal description and the street address or common designation, if any; for tangible personal property, its usual location); the plaintiff's title and the basis for it; the adverse claims the plaintiff wants resolved; the date as of which a determination is sought; and a prayer asking the court to determine the plaintiff's title against those adverse claims.

Adverse possession claims get a specific, heightened pleading rule. If the plaintiff's title rests on adverse possession, the complaint can't just assert the conclusion — it has to allege the specific facts that make up the adverse possession, the kind of detail a court needs to test whether the elements of adverse possession are met.

The date-of-determination requirement also deserves attention. Most complaints implicitly seek a determination as of the filing date, but if the plaintiff wants the court to fix title as of some other date, the complaint has to say so and explain why. That date can matter a great deal where interests have shifted over time.