Steinfeld v. State
In Steinfeld v. State, 37 Ariz. 389, 294 P. 834 (1930), the supreme court construed paragraph 4845 of the 1913 Civil Code, the remote predecessor to 42-17153, as treating a privately held tax lien superior to a prior mortgage held by the state.
The court based its holding on the last sentence of paragraph 4845, which provided that a tax lien "shall be prior and superior to all other liens and encumbrances upon the said property."
In response, the Legislature amended the last sentence to read:
"The lien shall be prior and superior to all other liens and encumbrances upon the property, except liens or encumbrances held by the state of Arizona." 1931 Ariz. Sess. Laws, ch. 106, 1.