Ralston v. Ralston
55 A.3d 736
| Pa. Super. Ct. | 2012Background
- Grantors Walter Francis Ralston Sr. and Elverta Ralston owned land in Decatur Township, Clearfield County, with minerals reserved by deed.
- The 1984 deed conveyed surface to Walter Francis Ralston Jr. but reserved minerals, ingress/egress, and a lifetime restraint during Grantors’ lifetimes.
- The 4th paragraph’s 'null and void' clause stated rights would vest in the grantee after Grantors’ deaths, not pass through the Grantors’ estate.
- Walter Francis Ralston Jr. conveyed the land to himself and his wife Patricia Ralston in 1991 as a Tenancy by the Entireties.
- Walter Jr. died in 1993; Elverta Ralston died in 1996; Patricia later conveyed her rights to Bernard Ralston in 1999.
- Appellants filed suit in 2011 to quiet title; Appellees sought a 5/7 ownership of the excepted rights; trial court granted appellees’ summary judgment and denied appellants’ summary judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the deed created an exception or a reservation | Appellants contend the null and void clause shows a reservation to grantors' heirs. | Appellees argue the language created an exception since rights existed and remained with grantors. | Deed created an exception; null and void language cannot create forfeiture |
| Whether the restraint on alienation was reasonable | Restraint during Grantors’ lifetimes is an unreasonable, voiding provision. | Restraint limited to lifetimes is reasonable and enforceable. | Restraint limited to lifetimes is reasonable; Walter’s conveyance during lifetimes violated the restraint |
Key Cases Cited
- Walker v. Forcey, 151 A.2d 606 (Pa.1959) (distinguishes reservation vs. exception where rights exist at grant)
- Lauderbaugh v. Williams, 186 A.2d 39 (Pa.1962) (absolute restraints void; limited restraints permissible)
- Estate of Royer v. Wineland Equip., Inc., 663 A.2d 780 (Pa.Super.1995) (restraint reasonableness measured by duration and context)
- Hyatt v. Hyatt, 417 A.2d 726 (Pa.Super.1979) (indefinite restraint deemed unreasonable)
- Consolidation Coal Co. v. White, 875 A.2d 318 (Pa.Super.2005) (primary tools for contractual interpretation of deeds)
- Kripp v. Kripp, 849 A.2d 1159 (Pa.2004) (ordinary meaning given to contract terms; interpret words)