Stoley, G. v. Wampler, G.
317 A.3d 1007
| Pa. Super. Ct. | 2024Background
- Plaintiffs (Stoley and Nehls) purchased a parcel (533 S.R. 130) whose deed boundaries were found to run through the house on the property, leading to a boundary dispute with the Wamplers (neighbors/family, defendants) over a roughly 10-foot strip near a line of pine trees.
- The property originally belonged to the Wampler family and was divided, with unclear boundaries between the two parcels (531 and 533 S.R. 130), leading to decades of informal use and unclear record descriptions.
- Plaintiffs relied on a surveyor's expert opinion and auctioneer's account that the line of pine trees, historically treated as a boundary, should establish the property line.
- Plaintiffs filed a quiet title action seeking title to the disputed area based on adverse possession, consentable lines, and equitable estoppel, also seeking a declaration to compel the Wamplers to file a corrective deed.
- The trial court found for Defendants, holding Plaintiffs did not prove possession, adverse possession, or consentable lines, but initially reformed the deed for equity’s sake. After a motion, the equitable reformation was struck, and the quiet title claim was denied, leading to Plaintiffs’ appeal.
- The Superior Court vacated the lower court judgment, finding insufficient factual findings/confused legal analysis, and remanded for correct application and additional findings about possession of the disputed area.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Correct standard under Pa.R.C.P. 1061 in quiet title | (b)(3), so possession not required; Wamplers should be compelled to file a corrective deed | Possession required under (b)(1); Plaintiffs did not prove possession | (b)(3) inapplicable; must examine possession under (b)(1) |
| Sufficiency of evidence on property line location | Surveyor's and auctioneer's evidence uncontradicted: tree line = boundary | Surveyor’s work compromised, evidence unpersuasive; never agreed on tree line | Lower court misapplied/overlooked key evidence; remand |
| Consideration of surveyor's compromise/settlement work | Trial court erred by factoring in compromise offer (inadmissible under Rule 408) | OK to consider because it goes to motivation and understanding | Trial court misapplied law/evidence, leading to confusion |
| Use of equitable reformation in deed dispute | Not available unless relief sought and mutual mistake shown | Only relief available is equitable reformation (but not requested by Plaintiffs) | Reformation unavailable under quiet title; requires new claim |
Key Cases Cited
- MacKubbin v. Rosedale Mem'l Park, Inc., 198 A.2d 856 (Pa. 1964) (reformation of a deed is an equitable remedy, not available in action at law to quiet title)
- Siskos v. Britz, 790 A.2d 1000 (Pa. 2002) (possession is a jurisdictional prerequisite for quiet title; ejectment required if plaintiff is out of possession)
- Moore v. Duran, 687 A.2d 822 (Pa. Super. 1996) (defines possession for quiet title; pleadings can be amended to conform to evidence)
- Doman v. Brogan, 592 A.2d 104 (Pa. Super. 1991) (deed errors are subject to reformation for mutual mistake)