In Re: The Matter of the Conservatorship of Mittie T. Alexander v. JB Partners, A Tennessee General Partnership
380 S.W.3d 772
Tenn. Ct. App.2011Background
- Conservator filed action seeking rescission of a warranty deed conveying Nashville real property to Ms. Anderson while preserving a life estate for Mittie.
- Conservator alleged Mittie lacked capacity to contract; deed to Anderson was unfair and executed without consideration.
- JB Partners intervened claiming superior title under the doctrine of equitable conversion through a contract with Anderson.
- Trial court held JB Partners had superior title and entered final judgment under Rule 54.02, with costs against Conservator.
- Court of Appeals reversed in part, remanded; held equitable conversion did not apply to defeat other asserted rights and reversed sanctions award.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Equitable conversion applicability | Alexander argues no equitable conversion should apply because no valid basis to vest JB Partners with superior title. | JB Partners contends contract for sale creates equitable conversion, giving superior title. | Doctrine does not automatically confer superior title; reversed. |
| Bona fide purchaser status | Alexander contends JB Partners is not a bona fide purchaser due to contract timing and lack of closing. | JB Partners maintains valid contract for sale and prerecord interests; entitled to protection as Bona fide purchaser. | Court held JB Partners stated a claim; not barred as a matter of law. |
| Unclean hands defense | Alexander asserts JB Partners acted with unclean hands due to amended contracts and delayed closing. | JB Partners argues no improper conduct; delay to resolve issues does not imply fraud. | Evidence did not show unclean hands; issue unsupported. |
| Attorney's fees for deemed admissions | Attorney’s fees for motion to deem admissions admitted were not properly sanctionable. | Trial court allowed fees as discovery sanction under broad discretion. | Reversed for lack of statutory/clear basis; American Rule applies. |
| Notice lis pendens waiver | Alexander argued waiver of lis pendens notice affected case. | JB Partners argued notice defect did not prejudice because equitable conversion issue resolved independently. | Issue deemed moot; not dispositive to judgment. |
Key Cases Cited
- Alley v. McLain’s Inc. Lumber and Construction, 182 S.W.3d 312 (Tenn. Ct. App. 2005) (equitable conversion applies when equity demands, not automatically at contract.)
- Campbell v. Miller, 562 S.W.2d 827 (Tenn. Ct. App. 1977) (treats vendor/purchaser relations under equitable conversion framework.)
- Riverside Surgery Center, LLC v. Methodist Health Systems, Inc., 182 S.W.3d 805 (Tenn. Ct. App. 2005) (unclean hands doctrine—equitable relief barred by bad faith conduct.)
- In re Adoption of E.N.R., 42 S.W.3d 26 (Tenn. 2001) (standard for appellate review of trial court discovery rulings.)
- Taylor v. Fezell, 158 S.W.3d 352 (Tenn. 2005) (American Rule on attorney’s fees; absent statutory/contractual provision, each bears own fees.)
- Steppach v. Thomas, 346 S.W.3d 488 (Tenn. Ct. App. 2011) (emphasizes reviewing a trial court’s orders, not just transcripts, for discovery rulings.)