Coe v. Hays
Maryland Court of Appeals
328 Md. 350, 614 A.2d 576 (1992)
- Written by Tammy Boggs, JD
Facts
In 1979, Gail A. Lewis executed a will in which he gave all his personal property and a life estate in specified real property (parcel 1) to Fanny C. Hays (defendant). Lewis devised the residue and remainder of his estate to his children (plaintiffs) in equal parts. More than eight years after executing his will, Lewis entered a contract to sell parcel 1 to specified buyers for $100,000. The buyers made a down payment. The real-estate contract required Lewis to convey marketable title to parcel 1, and the transaction was set to close on June 1, 1988. Subsequently, the parties to the contract executed an addendum to extend the closing date so that a “title problem” could be resolved. On June 19, 1988, prior to closing, Lewis died. Hays believed that, under the doctrine of equitable conversion, the proceeds from the sale of parcel 1 belonged to her as personal property. Lewis’s children sued Hays, alleging that proceeds from the sale of parcel 1 should be characterized as realty that belonged to the children. The trial court agreed, finding that a cloud on title had prevented equitable conversion from occurring and that the sales proceeds passed to the children under Lewis’s will. The intermediate appellate court reversed, finding that equitable conversion occurred. The Maryland Court of Appeals reviewed the matter.
Rule of Law
Issue
Holding and Reasoning (Bell, J.)
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