Love v. Elliott, 350 So. 2d 93 (Fla. App. 1977) is a case where Russell fraudulently got Mrs. Elliott, who was illiterate, to sign by her mark a deed conveying a much larger mineral interest in her property than she had agreed to sell. Russell then recorded his deed and sold his interest. The buyer was held to have good title, the court holding that a deed procured by fraud, unlike a forged deed, could be used to pass title to a bona fide purchaser.

On the other hand, Cumberland Capital Corp. v. Robinette, 331 So. 2d 709 (Ala. App. 1976) held that a signature procured by deceiving the grantor about what he was signing counted as a forgery. Harding v. Ja Laur Corp., 20 Md. App. 209 , 315 A. 2d 132 (1974) gives a similar result for a slightly different fraud.