Moffitt v. Moffitt
341 P.3d 1102
Alaska2014Background
- Leonard and Betty Moffitt created trusts in 1992; in 1995 they deeded part of their family farm to their son Tracy and his wife Kathy and executed a 1998 contract to transfer the remainder after their deaths.
- Leonard died in 2000; Betty was diagnosed with dementia in 2001; their daughter Linda became guardian/conservator for Betty, personal representative of Leonard’s estate, and successor trustee of the trusts.
- In 2005 Linda sued Tracy and Kathy seeking rescission or reformation of the 1995 deed and the 1998 contract, later amending to assert conversion, diminished capacity, undue influence, unconscionability, and unjust enrichment.
- The superior court granted summary judgment in part, holding statutes of limitations barred most claims (applying two‑year tort and three‑year contract statutes), but left open some restitution/loan claims; it also awarded attorney’s fees and costs to Tracy and Kathy.
- On appeal the Alaska Supreme Court considered whether Linda’s equitable claims are governed by statutes of limitations or by the equitable defense of laches, and whether legal claims remain subject to statutory time limits; the court vacated the dismissal and fee/cost awards and remanded for further proceedings on laches.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether rescission and reformation claims are controlled by statutes of limitations or by laches | Linda: equitable claims not governed by statutes of limitations; therefore statutes don't bar her claims | Tracy/Kathy: apply tort and contract statutes of limitations to bar claims | Court: equitable rescission and reformation are governed by laches, not statutes of limitations; reverse summary judgment and remand for laches analysis |
| Whether rescission/reformation claims are equitable or legal | Linda: she seeks court-ordered rescission/reformation (equitable relief) | Tracy/Kathy: characterized some relief as legal/subject to statutes | Court: claims are equitable (rescission in equity and reformation are equitable remedies) |
| Whether real property statutes of limitations apply | Linda: claims concern ownership/possession so real property statutes should govern | Tracy/Kathy: apply applicable statutes of limitations for tort/contract | Court: real property statutes do not apply because claims attack the validity of the sales contracts, not mere possession; tort/contract statutes apply to legal claims |
| Whether denial to consolidate with probate was an abuse of discretion | Linda: consolidation with probate was appropriate and denial prejudiced her | Tracy/Kathy: oppose consolidation; court gave procedural and substantive reasons | Court: denial was not an abuse of discretion; reasons (venue, broader probate issues, limited risk of prejudice) were adequate |
Key Cases Cited
- Alaska Civil Liberties Union v. State, 122 P.3d 781 (Alaska 2005) (discussing equitable relief and remedies)
- Knaebel v. Heiner, 663 P.2d 551 (Alaska 1983) (rescission in equity where court must decree rescission)
- Commercial Recycling Ctr., Ltd. v. Hobbs Indus., Inc., 228 P.3d 93 (Alaska 2010) (distinguishing rescission at law and in equity)
- Holmberg v. Armbrecht, 327 U.S. 392 (1946) (statutes of limitation are not controlling in equity)
- Castner v. First Nat’l Bank of Anchorage, 278 F.2d 376 (9th Cir. 1960) (statute of limitations did not apply to equitable claim)
- Bauman v. Day, 892 P.2d 817 (Alaska 1995) (claims attacking fairness of bargaining leading to conveyance are not governed by real property limitations)
- Kodiak Elec. Ass’n, Inc. v. DeLaval Turbine, Inc., 694 P.2d 150 (Alaska 1984) (laches is inapplicable to actions at law)
- United Nat’l Ins. Co. v. J.H. France Refractories Co., 668 A.2d 120 (Pa. 1995) (statutes of limitation provide guidance but do not control equitable relief)