Ansley v. Raczka-Long
293 Ga. 138
| Ga. | 2013Background
- Ansley conveyed two lots to Long by warranty deeds in 2010 and received two promissory notes in return.
- Long recorded the deeds but did not execute security deeds or pay Ansley; he died eight days after listing 149 Pearl Drive for sale.
- After Long's death, his girlfriend signed quitclaim deeds conveying the lots back to Ansley, which Ansley recorded in 2011.
- Ansley sought to set aside the quitclaims and assert an implied trust or unjust enrichment against Raczka-Long, who held title via year’s support.
- The probate court awarded title to Raczka-Long as year’s support; the administrator of Long’s estate later filed a Qui Timet to cancel the quitclaims, which Ansley opposed.
- The trial court granted summary judgment for Raczka-Long on the implied trust claims, leading to this appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does year’s support adjudicate title? | Ansley argues year’s support impairs her title. | Raczka-Long contends title awarded by year’s support is controlling. | Year’s support does not adjudicate title; validity of Long's title governs. |
| Adequacy of a resulting trust claim based on promissory notes? | Ansley asserts a resulting trust arose from Long’s repayment agreement. | Raczka-Long disputes creation of a resulting trust. | No genuine issue of material fact supports a resulting trust. |
| Whether a constructive trust should be implied due to unjust enrichment? | Ansley claims Long intended to deed back the property and benefited from Ansley's funds. | Raczka-Long argues no basis for a constructive trust as a matter of law. | There are disputed facts about Long's intent to deed back; constructive trust should not be decided as a matter of law. |
| Whether summary judgment was appropriate on the constructive trust claim? | Ansley argues summary judgment was improper due to factual disputes. | Raczka-Long maintains no triable issues exist. | Summary judgment was reversed in part; issues of constructive trust must go to trial. |
Key Cases Cited
- Stephens v. Carter, 215 Ga. 355 (Ga. 1959) (award does not adjudicate title)
- Edwards v. Edwards, 267 Ga. 780 (Ga. 1997) (trust implied; multiple bases for resulting trust)
- St. Paul Mercury Ins. Co. v. Meeks, 270 Ga. 136 (Ga. 1998) (constructive trust as equitable remedy)
- Conner v. Conner, 250 Ga. 27 (Ga. 1982) (evidence sufficient for implied trust question)
- Whiten v. Murray, 267 Ga. App. 417 (Ga. App. 2004) (implied trust existence when beneficial interest supported)
- Weekes v. Gay, 243 Ga. 784 (Ga. 1979) (constructive trust to prevent unjust enrichment)