Joyner v. Estate of Johnson
2012 D.C. App. LEXIS 24
| D.C. | 2012Background
- The disputed residence at 1216 42nd Street, N.E. Washington, D.C. originated from Hattie Mae Williams’s 1945 purchase and her 1963 will, which bequeathed her interest to Frances and Marie.
- In 1964 Williams’s property was transferred to Frances and Marie per the will; Marie later married Joyner in 1958, and in 1977 Marie conveyed her half to herself and Joyner as tenants by the entirety.
- In 1995 Frances executed a deed to Frances and Marie’s joint property, purporting to convey ‘all she has in improvements’ with Frances retaining a 50% fee simple; the deed names Frances as grantor and grantee and includes Marie as a witness.
- Frances’s and Marie’s wills (2004 and 1988 respectively) provided for life estates to Marie’s life with remainder to Frances’s children, and Marie’s will left her interest to Joyner; Frances later treated Frances as retaining ownership.
- In 2007 the Estate filed for partition by sale; the trial court ruled that Frances’s 1995 deed did not convey her interest away and that the Estate owned half the property as tenants in common, prompting this appeal.
- Jacob Thomas testified as an expert for the Estate on title interpretation; the court allowed his testimony over Joyner’s objection, and the court found the 1995 deed ambiguous only to the extent extrinsic evidence clarified Frances’s intent.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the 1995 deed convey Frances’s interest to Joyner and Marie? | Joyner | Estate | No; 1995 deed did not transfer Frances’s half to Joyner. |
| Is the 1995 deed ambiguous requiring extrinsic evidence to determine Frances’s intent? | Joyner | Estate | Deed not ambiguous on its face; extrinsic evidence considered but did not show transfer. |
| May extrinsic evidence be used to interpret the 1995 deed’s meaning? | Joyner | Estate | Extrinsic evidence permissible; nonetheless it did not support transfer to Joyner and Marie. |
| Was Jacob Thomas properly admitted as an expert on title, given credentials? | Joyner | Estate | Thomas qualified by experience; admission not an abuse of discretion. |
| Did the trial court err in granting partition by sale to the Estate based on its interpretation of the 1995 deed? | Joyner | Estate | Affirmed; Estate owns half, and partition by sale appropriate. |
Key Cases Cited
- Hinton v. Sealander Brokerage Co., 917 A.2d 95 (D.C. 2007) (clear errors standard for non-jury review; substantial evidence.)
- Dyer v. Bilaal, 983 A.2d 349 (D.C. 2009) (interpretation of contracts under objective law of contracts.)
- Foundation for the Pres. of Historic Georgetown v. Arnold, 651 A.2d 794 (D.C. 1994) (extrinsic evidence may guide contract interpretation when necessary.)
- Washington Props., Inc. v. Chin, Inc., 760 A.2d 546 (D.C. 2000) (ambiguity defined by susceptibility to multiple interpretations; plain language governs.)
- Jones v. United States, 990 A.2d 970 (D.C. 2010) (expert qualification can be by experience, not only formal credentials.)
- Dyas v. United States, 376 A.2d 832 (D.C. 1977) (establishes standard for admission of expert testimony.)