Roberson v. Manning
268 P.3d 1090
Alaska2012Background
- In 1997 Roberson and Manning jointly purchased a mobile home; title remained with the bank/original owners with a blank transferee line.
- The couple lived in the mobile home off and on, then rented it to Roberson's daughter after 1999.
- In June 2005 Manning sought a protective order against Roberson; at a hearing he stated he would give Roberson his share of the home.
- By August 2006 Manning titled the mobile home in his name alone and soon after agreed to sell it to Dennis Wilson for $10,000.
- Wilson paid $2,000 down and later acquired the title; Roberson remained living in the home and later faced eviction.
- The superior court found no delivery of Manning's share (no title transfer) and that Wilson was a good-faith purchaser; the court divided proceeds and granted possession to Wilson; on appeal, Roberson challenged both conclusions and the case was remanded for further findings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did Manning transfer his share to Roberson despite no title delivery? | Roberson argues Manning intended to give her the home share and delivery occurred by possession. | Manning contends the gift was invalid or delivered only by future promise, with lack of title transfer and possible duress. | Vacated and remanded to determine donative intent and delivery, not solely rely on title transfer. |
| Is Wilson a good-faith purchaser given the title and occupancy facts? | Roberson contends Wilson knew of Roberson's occupancy and paid below market value, so not a good-faith purchaser. | Wilson asserts he acted in good faith and paid value, relying on Manning's title. | Vacated and remanded for further findings on Wilson's knowledge, inquiry into occupancy, and status as a good-faith purchaser. |
Key Cases Cited
- Young v. Embley, 143 P.3d 936 (Alaska 2006) (standard for appellate review; internal citations omitted)
- Dodson v. Dodson, 955 P.2d 902 (Alaska 1998) (cited for analytical framework in appeals)
- State Farm Mut. Auto. Ins. Co. v. Clark, 397 F.Supp. 745 (D. Alaska 1975) (interpretation of statutory predecessors related to title and possession)
- Frantz v. First Nat'l Bank of Anchorage, 584 P.2d 1125 (Alaska 1978) (good-faith purchaser and inquiry duties in transactions)
- American Standard Credit, Inc. v. National Cement Co., 643 F.2d 248 (5th Cir. 1981) (distinction between voidable title and void title in pass-through sales)
- Ware v. Ware, 161 P.3d 1188 (Alaska 2007) (essential elements of gift intentions and delivery)
