In St. Paul Title Insurance Corp. v. Owen, why was the conveyance from James and Cheryl Owen to Dennis Carlisle deemed to be by special warranty deed? Question 3 options: a) The transaction occurred within the State of Alabama. b) Carlisle paid fair market value for the property conveyed. c) The transaction occurred before 1998. d) The deed delivered to Carlisle used the words "grant, bargain, sell and convey