In what circumstances will a plaintiff be able to bring a claim for damages against a defendant for an unauthorized reconveyance?

[such] as where a deed has been forged or has not been delivered." (Firato v. Tuttle, supra, 48 Cal.2d at p. 139.) In the case of unauthorized reconveyances, such as the one in the case before it, the court found that former Civil Code section 2243² "would protect innocent purchasers for value who take without any notice that the conveyance by the trustee was unauthorized . . . ." (Ibid.) Defendants in Firato were innocent purchasers for value and plaintiffs could not plead otherwise. Consequently, plaintiffs could not state a cause of action and the demurrers were properly sustained.