Sam entered into a contract to sell Blackacre to Betty. On the date agreed upon, Betty paid Sam the purchase price, and he executed a deed to Blackacre in her favor. The next day, Betty learned that Sam had not been the holder of record title to Blackacre, and that he claimed to have acquired legal title to Blackacre by adverse possession. If Betty brings an action against Sam for recovery of the amount she paid him, judgment should be for:
a) Betty, because Sam failed to convey marketable title to Blackacre.
b) Sam, but only if he had already established his title arising from adverse possession in a judicial proceeding.
c) Sam, if he conveyed title to Betty via a quitclaim deed.
d) Sam, because title obtained by adverse possession is marketable title.