Van Middlesworth v. Century Bank & Trust Co.

In March 1995, Rodney Van Middlesworth and Sue Van Middlesworth (plaintiffs) entered a written agreement to purchase 500 acres of farmland from Harold Piper. Harold later died. The Middlesworths brought suit against Harold’s successor trustee, Century Bank & Trust Company, Timothy Piper, and next friends Leon Piper and Phillip Piper (defendants), seeking specific performance and damages for breach of contract. Testimony established that a series of transactions between Rodney and Harold for the sale of corn and beans in 1992 and 1993 reflected a diminishing ability on Harold’s part to understand the nature of the transactions. Rodney also testified that interactions with Harold in April and May 1995 caused Rodney to conclude that Harold did not understand the words being exchanged between them. Testimony from witnesses including a clinical psychologist, a neurologist, and a physician specializing in geriatric neurology indicated that Harold was suffering from dementia as of March 1995. The trial court concluded that Harold was mentally incompetent at the time of the agreement and that reasonable people in the Middlesworths’ position would have been put on notice that further inquiry into Harold’s mental competence was necessary before executing the agreement. The Middlesworths appealed. The Michigan Court of Appeals granted certiorari.