Layne v. Layne, 74 So. 3d 161

In 1985, Appellant, his father, and Appellee held a townhouse as joint tenants with right of survivorship (1/2 to Appellant, 1/2 to father/appellee).
In 1990, Appellant quitclaimed his interest to his father and Appellee, acknowledging they were not married at that time.
Nine years later, the father died intestate; Appellant and his sister were sole beneficiaries.
Appellee sought Subsequent Summary Administration, arguing Appellant’s 1990 quitclaim and a 1990 conveyance left him no interest.
The trial court distributed the estate’s interest, giving Appellee a 1/2 share and Appellant’s sister the other 1/2; Appellant received nothing.
The appellate court reverses, holding Appellant retains an after-death interest under intestacy and that the quitclaim did not bar his potential future interests.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether after-acquired title applies to quitable interests here	Appellant	Appellee	Not applicable; no fraud or inequity; after-acquired title doctrine does not apply
Whether a quitclaim conveys future intestate interest	Appellant	Appellee	Quitclaim conveys only current interests; future intestate rights not conveyed
How the estate's and heirs' interests vest after dissolution of marriage	Appellant and sister share estate interests equally	Appellee	Estate holds 1/2; upon dissolution, parties become tenants in common; result is 1/4 each to Appellant and sister

Lobean v. Trustees of the Internal Improvement Fund, 127 So. 2d 98 (Fla.1961) (legal/estoppel related to after-acquired title)
Diaz v. Rood, 851 So. 2d 843 (Fla.2d DCA 2003) (conveyance of expectancy; limitations of future interests)
Blitch v. Sapp, 194 So. 328 (Fla.1940) (quit-claim yields only grantor's interest at conveyance)
Van Pelt v. Estate of Clarke, 476 So. 2d 746 (Fla.1st DCA 1985) (mere quitclaim or release not estoppel against after-acquired interest)
Aills v. Boemi, 29 So. 3d 1105 (Fla.2010) (undisputed facts reviewed de novo; standard of review)