Turner v. Wells Fargo Bank, N.A., 2012 MT 213

John Turners acquired Shepherd property via quitclaim from James Turner in 2006 after a debt was secured by a Wells Fargo Deed of Trust.
James and Julie Turner obtained a $169,540 SmartFit Home Equity loan from Wells Fargo in 2005–2006, later paying it down using sale proceeds.
Wells Fargo advanced additional funds to Julie after the sale, creating a lien on the Shepherd property not released in Wells Fargo’s records.
The Deed of Trust remained recorded against the Shepherd property, undisclosed to the John Turners at closing, who later acquired title.
In 2009 Wells Fargo refused to release the Deed of Trust; the Turners sought to quiet title in 2010 and 2011 for release.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Wells Fargo owed a contractual release obligation	Turners claim third-party beneficiary rights to release.	Bank argues lack of contract and standing; release required written close per agreement.	No standing; no enforceable contract obligation by Wells Fargo to release.
Whether promissory/equitable estoppel require release	Equitable estoppel applies; bank should release lien.	Estoppel claims fail; no clear promise or reliance by Turners.	Neither promissory nor equitable estoppel established.

Dick Anderson Constr., Inc. v. Monroe Constr. Co., 2009 MT 416 (Mont. 2009) (intended third-party beneficiary requires explicit intent to benefit)
Kurtzenacker v. Davis Surveying, Inc., 2012 MT 105 (Mont. 2012) (incidental beneficiary lacks standing to enforce)
Diaz v. Blue Cross & Blue Shield, 2011 MT 322 (Mont. 2011) ( Restatement §302 intended beneficiary test)
Keil v. Glacier Park, 188 Mont. 455 (Mont. 1980) (four-element promissory estoppel test)
In re Estate of Stukey, 2004 MT 279 (Mont. 2004) (six-element equitable estoppel test)
Cascade Development, Inc. v. City of Bozeman, 2012 MT 79 (Mont. 2012) (equitable estoppel solidarity with justice and fair dealing)