Langman v. Alumni Association of the University of Virginia
Supreme Court of Virginia
442 S.E.2d 669 (1994)
In 1986, Dr. Margaretha W. Langman (plaintiff) and Caleb N. Stowe deeded commercial property to the Alumni Association of the University of Virginia (association) (defendant). The deed contained a mortgage assumption clause, which would have allowed the responsibility for the mortgage to pass to the association. Association representatives never signed the deed, but the association acknowledged its receipt, despite the association director's privately expressed reservations about inclusion of the mortgage assumption clause. Thereafter, Stowe continued making mortgage payments out of the property's revenue, and when that revenue became insufficient, Stowe made the payments from his own funds. The association recorded Stowe's personal payments as a debt to be repaid to Stowe. In 1988, Stowe forgave this debt and the association treated his payments as charitable contributions to the association. Later, Stowe became insolvent, and the bank holding the mortgage notified Langman that she was now responsible for the mortgage payments. Langman made the payments but reserved her rights to reimbursement and demanded that the association assume responsibility for future payments. When the association refused, Langman sued the association. The trial court ruled in the association's favor, finding that the mortgage assumption clause was mistakenly inserted in the deed and never knowingly accepted by the association. Langman appealed to the Supreme Court of Virginia on two grounds: (1) the trial court improperly admitted parol evidence that contradicted the deed's plain language, and (2) the association accepted the deed pursuant to its terms and could not disavow its mortgage obligation 30 months later.
Rule of Law
Holding and Reasoning (Keenan, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 97,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.
Here's why 175,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 14,000 briefs, keyed to 188 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.