Terrell Taylor (Taylor) owned a ranch in fee simple. In 1991, Taylor conveyed the ranch to himself and Lucy Canterbury (plaintiff) as joint tenants. In 1997, Taylor, as joint owner, conveyed the property to himself and Canterbury as tenants in common. This deed stated clearly that Taylor’s intent was to sever the joint tenancy and create a tenancy in common. After Taylor’s death, Canterbury filed a quiet-title action, seeking a ruling that she was the sole owner of the ranch as the surviving joint tenant. The trial court granted Canterbury’s request, finding that the 1997 deed failed to sever the joint tenancy. The court of appeals affirmed. The Colorado Supreme Court granted the petition of Noah Taylor (defendant), Taylor’s personal representative, for certiorari.