Russell Ulrich claimed ownership of 38 acres of land through a chain of title dating back to a

conveyance from the Loefler family to Ulrich's family in 1888. The Loeflers' claim to the

land dates to an unrecorded deed prior to 1888. The Pennsylvania Game Commission (Commission) claims ownership to the same parcel through a conveyance from Handwerk.

The origin of the problem is due apparently to a change in how land surveyors do surveys.

The Commission argues that because the basis of Ulrich's claim is an unrecorded deed, his

title is invalid. Does the Commission have a legitimate defense? Commonwealth v. Ulrich,

565 A.2d 858 (1989).