Charles Adamson v. Jonathan Adamson, 2020 SC 0175

Background

Rickie Adamson died in 2013; his wife Loueva sought probate of a holographic will that left everything to her; the estate settlement was approved in 2014.
The farm had been purchased jointly by Rickie and Loueva with rights of survivorship; Loueva later sold the farm to Charles and his wife Vanda in May 2014; that deed was recorded and not contested.
Jonathan and Paul obtained a forensic report concluding the will was forged and sued in Union Circuit Court (2015); mediation occurred June 29, 2017 and produced a written mediation agreement containing Clauses 8–9 (the “farm agreement”) calling for a new sale/LLC split among the three brothers and Charles to manage Bluegate Farms, LLC.
Charles later refused to sign the written mediation agreement, claimed the writing did not match the oral terms, obtained new counsel, and invoked the Statute of Frauds when Jonathan and Paul sought enforcement.
The trial court enforced the mediation agreement (finding the Statute of Frauds inapplicable or satisfied because Arnett, Charles’s former attorney, signed as his agent, and finding Charles an agent for Vanda); the Court of Appeals affirmed.
The Kentucky Supreme Court held the farm agreement was a sale of land covered by the Statute of Frauds, Arnett lacked authority to bind Charles (and could not bind Vanda), and Charles was not shown to be Vanda’s agent; it reversed as to Clauses 8–9 and remanded to vacate enforcement of the farm transfer portion while leaving the estate-related settlement intact.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the mediation farm agreement is subject to the Statute of Frauds	Jonathan & Paul: The mediation agreement is a settlement instrument, not a land sale, so the Statute of Frauds does not apply	Charles: The farm transfer is a sale of land and thus must comply with the Statute of Frauds	Held: Statute of Frauds applies—the farm agreement is a contract for sale/transfer of land and is subject to KRS 371.010(6)
Whether a signed writing satisfying the Statute exists because Arnett (Charles’s former attorney) signed the mediation agreement	Jonathan & Paul: Arnett signed as Charles’s authorized agent, satisfying the Statute	Charles: Arnett lacked authority to sign on his behalf for the farm transfer	Held: Arnett did not have authority to bind Charles (and was not Vanda’s attorney); no signed writing by the parties to be charged exists; Statute not satisfied
Whether Charles had apparent authority to bind his wife Vanda to the farm agreement	Jonathan & Paul: Charles’s statement he would “tell her to” go along demonstrated apparent authority	Charles: No evidence Vanda held him out as her agent; his statement alone is insufficient	Held: Mere declarations by the alleged agent are insufficient; no apparent authority shown; Vanda not bound
Whether equitable estoppel or necessity of Vanda as party affects enforcement	Jonathan & Paul: Equitable estoppel and non-necessity of Vanda permit enforcement despite missing signatures	Charles: Equitable estoppel cannot override Statute of Frauds and Vanda is a necessary party to land-transfer relief	Held: Equitable estoppel cannot defeat the Statute; because enforcement is barred, Vanda is not a necessary party for further proceedings, but lower courts should heed joinder rules in title disputes

Key Cases Cited

Bennet v. Horton, 592 S.W.2d 460 (Ky. 1979) (Statute of Frauds bars parol sale/transfer of land)
Smith v. Williams, 396 S.W.2d 296 (Ky.) (oral land contracts unenforceable once statute raised)
Smith v. Ballou, 277 S.W. 286 (Ky.) (writing must be signed by the party to be charged)
Nazar v. Branham, 291 S.W.3d 599 (Ky. 2009) (existence/scope of agency is a question of law when facts undisputed)
Kindred Nursing Ctrs. Ltd. P’ship v. Brown, 411 S.W.3d 242 (Ky. 2011) (agent declarations inadmissible to establish agency/apparent authority)
Lazarus’ Adm’x v. Hall, 152 S.W.2d 592 (Ky. 1941) (marital relations do not presumptively create agency between spouses)
Bitzer v. Moock’s Ex’r & Trustee, 271 S.W.2d 877 (Ky. 1954) (contracts conveying real and personal property may be severable)
Rice & Hutchins’ Cincinnati Co. v. J.W. Croghan & Co., 184 S.W. 374 (Ky. 1916) (agent’s bare declarations cannot establish authority)
Duff v. Turner, 256 S.W. 1105 (Ky. 1923) (Statute applied to parol surrender of disputed land)
Owen v. Dayson, 562 S.W.2d 647 (Ky. 1977) (Statute applied to secondary conveyances such as lease assignments)