Trixie owns a parcel of land. She doesn't pay her property taxes, so the state files a tax lien on the property, creating an encumbrance. Trixie then sells the land to Sam but doesn't tell him about the tax lien. Sam then sells the property to Gary and gives him a special warranty deed. Gary neglects to obtain a title insurance policy when purchasing the real estate. When the state comes to collect the unpaid taxes from the property's current owner, Gary, what recourse does he have?