Christian v. Cotten
In Christian v. Cotten, 1 Ariz. App. 421, 403 P.2d 825 (1965), a purchaser of a tax lien certificate sued the record owner of property, the United States, which held a mortgage and two judgment liens on the property, as well as the county treasurer, to foreclose redemption rights.
Without any objection from the treasurer, the trial court entered an order directing the treasurer to issue the deed subject to the mortgage and judgment liens of the United States.
A non-party to the case, the county (not the county treasurer), appealed. Id. at 423-24, 403 P.2d 827-28.
The court held that the county had no right to appeal because it had not been a party to the case and had not been aggrieved by the decision as it had no pecuniary interest in the matter because all of the delinquent taxes and charges had been paid. Id. at 424, 403 P.2d 827.
In Christian, the question was whether the county, a non-party, could appeal the foreclosure judgment.
The case did not present the question of whether a party could enforce a judgment against a non-party.