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Roberson v. Manning
268 P.3d 1090
Alaska
2012
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Background

  • 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)
Read the full case

Case Details

Case Name: Roberson v. Manning
Court Name: Alaska Supreme Court
Date Published: Jan 27, 2012
Citation: 268 P.3d 1090
Docket Number: No. S-13371
Court Abbreviation: Alaska