Deed/Title Recorded after Death...?

[Lee Bailey]

Talked to a seller today, and her exact words were: 

"I have been advised by the title insurance company that because the deed for the property from my grandparents to my uncle was recorded after their death, I need to have a quiet title process initiated."

The property is in Virginia.

Was she given sound advice, or is there another avenue around this? Would be great to hear from any title experts...