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Allen v. Hall

Utah Supreme Court
148 P.3d 939 (2006)


After David Allen (plaintiff) and Sarah Satterfield divorced, their divorce decree awarded Satterfield the former couple’s home. The decree conditioned Satterfield’s ownership of the home upon her making timely mortgage payments and living within 50 miles of Salt Lake City until their youngest child turned 18. Upon Satterfield’s failure to comply with either condition, the home would revert to Allen. The deed transferring the property to Satterfield contained the same restrictions. Satterfield took possession of the home and refinanced it several times over the years before conveying the property to Thomas Hall (defendant) in 1998. Hall assumed the existing mortgages. While Satterfield remained within 50 miles of the city when she initially sold the property to Hall, in 1999, she moved away from Utah, awakening Allen’s reversionary interest. Allen sued to quiet title against Hall. The court of appeals concluded that Allen was entitled to the home, but was required to pay all debts associated with the property and to reimburse Hall for the value of Hall’s improvements to the property pursuant to the Utah Occupying Claimants Act (the act). Allen appealed.

Rule of Law


Holding and Reasoning (Nehring, J.)

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