Sleepy Hollow Ranch LLC v. Robinson
2012 Mo. App. LEXIS 529
| Mo. Ct. App. | 2012Background
- Appellants Sleepy Hollow Ranch, LLC, the Estate of Jim Blunk, and the Blunk Living Trust appeal the Amended Judgment on multiple grounds, including whether deeds to Priscilla Robinson should be set aside for undue influence or lack of capacity, and whether the Homeplace title was divested to Robinson or retained by Blunks via adverse possession.
- Jim Blunk deeded the Homeplace and the Mark Twain house to Robinson in Feb 2006; prior to that, he resided in the Mark Twain house with Robinson who managed his finances and medical care.
- Tessie Lombard originally owned the Homeplace; it passed to the College of the Ozarks, which later conveyed the Homeplace to Sleepy Hollow Ranch; the College purportedly quitclaimed the Homeplace to the Estate in 2009.
- Joe and Donna Blunk occupied the Homeplace since 1976; their possession became adverse to Tessie’s interests by 1990 and ultimately was found to be hostile, open, and continuous for ten years, leading to a ruling in favor of Blunks via adverse-possession theory.
- Robinson cross-appeals, challenging (a) a $100,000 gold-conversion award to Appellants and (b) a $2,500 damages award for a 1972 pickup; the court reversed/remanded on the pickup issue but affirmed the gold-conversion ruling.
- The trial court found no undue-influence invalidating the deeds but did award damages for conversion of the gold and the pickup, and it ruled that the Homeplace grant to Robinson was voidable by adverse possession principles in favor of Blunks; the appellate court affirmed some rulings and reversed/remanded others.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Undue-influence claim to set aside deeds | Sleepy Hollow argues a confidential relationship and evidence supports presumption. | Robinson contends no clear, cogent proof of undue influence; beneficiary’s influence not coercive. | Denied; no thwarting of free agency; presumption not proven. |
| Adverse-possession of the Homeplace by Blunks | Appellants assert stronger evidence required due to family ties and notices from Tessie. | Robinson argues insufficient hostile, open, exclusive possession. | Affirmed; Blunks’ adverse possession supported; title quieted in Blunks. |
| Robinson’s gold-conversion liability | Estate/Appellants showed Robinson withheld $100,000 in gold. | Robinson denied possession/withholding; contested value. | Affirmed; $100,000 conversion award sustained. |
| Damages for the 1972 pickup | Appellants proved value and wrongful withholding. | Robinson denied possession and value; no evidence of value. | Reversed and remanded for new trial on this issue only. |
| Cross-appeal regarding Homeplace conveyance | Mooted by adverse-possession ruling; no separate remedy. |
Key Cases Cited
- Landers v. Sgouros, 224 S.W.3d 651 (Mo.App.2007) (standard of review for court-tried equitable claims)
- Tobias v. Korman, 141 S.W.3d 468 (Mo.App.2004) (confidential relationship alone not enough for presumed undue influence)
- Duvall v. Brenizer, 818 S.W.2d 332 (Mo.App.1991) (presumption of undue influence requires evidence from which undue influence can be inferred)
- Ruestman v. Ruestman, 111 S.W.3d 464 (Mo.App.2003) (burden on plaintiff to prove undue influence; presumption shifts burden to fiduciary)
- Hock, Estate of, 322 S.W.3d 574 (Mo.App.2010) (necessity to prove undue influence when presumption arises)
- Tallent v. Barrett, 598 S.W.2d 602 (Mo.App.1980) (stronger evidence of adverse possession in presence of family relationship)
- Lancaster v. Neff, 75 S.W.3d 767 (Mo.App.2002) (recognition that courts may require stronger adverse-possession proof with family parties)
- Weaver v. Helm, 941 S.W.2d 804 (Mo.App.1997) (adverse-possession standards and factors)