Estate of Price v. Hodkin
2019 UT App 137
Utah Ct. App.2019Background
- Two sisters, Virginia N. Price and Catherine N. Story, received two deeds in 1945 conveying property to them as joint tenants with right of survivorship.
- Catherine died in 1966; executor Robert E. Mark petitioned and the court authorized a 1966 deed conveying Catherine’s surface interest to Virginia in satisfaction of a debt, while reserving one-half of all oil, gas, and minerals for Catherine’s estate; the 1966 Deed was recorded.
- For decades thereafter Virginia (and successors including Amy Price) made intermittent payments to Catherine’s beneficiaries and Virginia’s successors collected proceeds consistent with the 1966 transaction.
- Amy (successor to Virginia’s interest) filed a quiet title action in 2013 seeking to void the 1966 Deed and assert that, by survivorship, Virginia received the entire property (including minerals) when Catherine died.
- Defendants (Catherine’s beneficiaries) argued the joint tenancy may have been severed pre-1966 or that the 1966 transaction conveyed mineral rights to Catherine’s estate; they also asserted equitable defenses including laches, estoppel, waiver, and res judicata.
- The district court granted summary judgment for Amy; the Utah Court of Appeals reversed, holding laches barred Amy’s quiet title claim based on long, unexplained delay and prejudice to defendants from lost witnesses and records.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Amy’s quiet title claim is barred by laches | Amy: Delay was not unreasonable; any knowledge was constructive and Defendants equally had notice so laches should not apply | Defs: 47-year delay after constructive notice was unreasonable and prejudiced defendants | Court: Amy unreasonably delayed (47 years) after constructive notice; laches applies |
| Whether joint tenancy was severed before Catherine’s death | Amy: No recorded evidence of severance; joint tenancy survived so Virginia acquired full title by right of survivorship | Defs: Sophistication of parties and conduct after Catherine’s death permit an inference of an unrecorded severance (e.g., strawman) | Court: Summary judgment improper on merits because laches prevents resolving merits now; lost witnesses/evidence prejudice defendants |
| Whether 1966 transaction conveyed mineral rights to Catherine’s estate | Amy: Catherine’s estate had no interest to convey; transaction void as lacking consideration or was mistaken | Defs: The agreement and decades of performance show an effective conveyance/recognition of mineral split | Held: Court did not resolve substantive conveyance issue on appeal; remanded for further proceedings because equitable defenses bar summary judgment for Amy |
| Whether defendants suffered prejudice from the delay | Amy: No prejudice shown; defendants had record notice too | Defs: Key witnesses and records are lost; proof of severance (if any) is now unattainable | Court: Prejudice shown—witnesses and business records are gone, making fair resolution of severance issue unlikely |
Key Cases Cited
- Insight Assets, Inc. v. Farias, 321 P.3d 1021 (Utah 2013) (equity aids the vigilant; laches elements explained)
- Fundamentalist Church of Jesus Christ of Latter-Day Saints v. Horne, 289 P.3d 502 (Utah 2012) (laches discussed in equitable relief context)
- Veysey v. Nelson, 397 P.3d 846 (Utah Ct. App. 2017) (mixed question of law and fact for laches)
- Nilson-Newey & Co. v. Utah Res. Int’l, 905 P.2d 312 (Utah Ct. App. 1995) (constructive knowledge can trigger laches)
- In re Estate of Knickerbocker, 912 P.2d 969 (Utah 1996) (intent governs severance of joint tenancy; recorded self-conveyance effective)
- Crowther v. Mower, 876 P.2d 876 (Utah Ct. App. 1994) (burden to prove delivery of deed severing joint tenancy)