William J. Knapp and Rosalea M. Knapp v. The Estate of Carl R. Wright and Joan M. Wright
76 N.E.3d 900
| Ind. Ct. App. | 2017Background
- The Wrights owned a 56-acre parcel with a private lake. In 1999 they leased a portion to their daughter and son‑in‑law, the Knapps, with an attached (but missing) Exhibit A describing boundaries and an option to purchase.
- In 2004 the parties executed a Real Estate Contract that referenced an Exhibit A (not attached) and stated the properties’ approximate boundary lines would be surveyed upon payoff; no written legal description was included in the contract.
- The Knapps made payments under the land contract and occupied the property; disputes arose over whether the contract conveyed one acre (Wrights’ position) or three acres plus lake/water rights (Knapps’ position).
- The trial court granted the Wrights partial summary judgment holding the Real Estate Contract unenforceable under the Statute of Frauds for lack of a reasonably certain description, and later awarded the Wrights $24,000 for fair market rental value while the Knapps remained on the land.
- The trial court also ordered the Knapps’ lis pendens removed after entering a final appealable judgment; the Wrights sold the property at auction. The Knapps appealed; the appellate court affirmed.
Issues
| Issue | Plaintiff's Argument (Knapps) | Defendant's Argument (Wrights) | Held |
|---|---|---|---|
| Whether the Real Estate Contract satisfies the Statute of Frauds description requirement | Contract’s reference to “Exhibit A” and a drawing found later supply a sufficient description | Contract lacks any attached Exhibit A or contemporaneous drawing; description is not reasonably certain | Contract unenforceable as a matter of law for failing to describe land with reasonable certainty; partial summary judgment for Wrights |
| Whether exceptions (acquiescence/estoppel/part performance) defeat the Statute of Frauds defense | Parties’ long occupation and payments create equitable exceptions allowing enforcement | No genuine issue of material fact was preserved below proving an applicable exception | Knapps abandoned/acquiesced arguments below; appellate court declined to consider new arguments; exceptions not applied |
| Whether the $24,000 damages award (fair market rental) was speculative | Appraisal provided only a single‑day rental opinion; court’s monthly rates for prior periods are speculative | Appraiser testified rental rates were stable; trial court reasonably extrapolated values | Award within scope of the evidence; no abuse of discretion |
| Whether removal of lis pendens was premature | Lis pendens removal was premature because Knapps intended to appeal; no final determination until appeal resolved | Trial court entered a final appealable judgment disposing of title and damages; statute requires satisfaction entry upon final determination | Trial court correctly removed lis pendens after entering a final appealable judgment; affirmed |
Key Cases Cited
- Rogers v. Martin, 63 N.E.3d 316 (Ind. 2016) (summary judgment standard)
- Coca‑Cola Co. v. Babyback’s Int’l, Inc., 841 N.E.2d 557 (Ind. 2006) (writing must contain essential terms without resort to parol evidence)
- Schuler v. Graf, 862 N.E.2d 708 (Ind. Ct. App. 2007) (elements of enforceable land contract under Statute of Frauds)
- Cripe v. Coates, 116 N.E.2d 642 (Ind. App. 1954) (description need only furnish means of identification with extrinsic aid)
- Johnson v. Sprague, 614 N.E.2d 585 (Ind. Ct. App. 1993) (contracts must be reasonably definite to enforce specific performance)
- UFG, LLC v. Southwest Corp., 784 N.E.2d 536 (Ind. Ct. App. 2003) (final appealable judgment qualifies as "final determination" for lis pendens statute)