Aletha Carroll Combs v. Karen Reneer

CourtCourt of Appeals of Kentucky
DecidedAugust 17, 2023
Docket2022 CA 000362
StatusUnknown

This text of Aletha Carroll Combs v. Karen Reneer (Aletha Carroll Combs v. Karen Reneer) is published on Counsel Stack Legal Research, covering Court of Appeals of Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Aletha Carroll Combs v. Karen Reneer, (Ky. Ct. App. 2023).

Opinion

RENDERED: AUGUST 18, 2023; 10:00 A.M. TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals

NO. 2022-CA-0362-MR

ALETHA CARROLL COMBS APPELLANT

APPEAL FROM GRAYSON CIRCUIT COURT v. HONORABLE KENNETH H. GOFF, II, JUDGE ACTION NO. 18-CI-00083

KAREN RENEER; BARBARA MCCRACKEN; CAPITAL ONE NA CORPORATION; COLUMBUS MCCRACKEN; JEFFREY RENEER; LVNV FUNDING, LLC; AND MIDLAND FUNDING, LLC APPELLEES

OPINION AFFIRMING

** ** ** ** **

BEFORE: ACREE, EASTON, AND JONES, JUDGES.

EASTON, JUDGE: Aletha Carroll Combs (“Combs”) appeals from the Grayson

Circuit Court’s Order, entered on March 3, 2022, approving a Master

Commissioner sale of real property Combs owned jointly with the Appellee

(“Reneer”). Reneer was the successful bidder at the partition sale with a bid of $1.00. Combs argues the trial court erred by ruling the sale price was not so low

compared to the value of the property as to shock the conscience. The trial court

correctly applied the law, which required consideration of all the attendant

circumstances, not just the sales price. Because the trial court did not abuse its

discretion, we affirm.

FACTUAL AND PROCEDURAL HISTORY

In June 2009, Combs purchased property located at 1799 Walnut

Grove Road, in Caneyville, Kentucky. The property consists of a home and

approximately five surrounding acres. Combs states she paid $31,000.00 down,

with the remaining $74,000.00 of the sale price being secured by a mortgage held

by the sellers (the “McCrackens”).

On June 15, 2012, Reneer became a joint owner of the property with

Combs. The 2012 deed created a joint tenancy with right of survivorship.

Significantly, both Combs and Reneer acknowledged the value of the property in

2012 was $71,000.00, an amount less than the recent mortgage amount. A new

mortgage was filed by the McCrackens with both Combs and Reneer as

mortgagors, with a debt of $62,336.09, the balance owed on the previous debt.

It is undisputed Reneer made all the mortgage payments since June

15, 2012. Further, Reneer has had possession and has resided at the subject

property since 2012. As a result, Reneer has been solely responsible for its daily

-2- maintenance. Reneer testified the mortgage balance owed on the subject property

was $2,854.14 as of February 2, 2022. Reneer testified she intended to make

monthly payments until the mortgage was paid in full.

On April 2, 2018, Combs filed an action in the Grayson Circuit Court

pursuant to KRS1 389A.030 for a partition sale of the property and for the trial

court to award her share of the proceeds to her. In her petition, Combs alleged

Reneer deprived Combs of the use and enjoyment of personal property located and

stored on the premises, which is a separate issue from the value of the real estate.

On February 10, 2021, Combs filed a “Motion for Judgment Upon the

Pleadings and to Refer to Master Commissioner.” This almost three-year delay

resulted at least in part from multiple judgment liens attached to the property for

unpaid debts of the parties. These lienholders had to be made parties to the case

and their liens addressed by default judgments, or otherwise, prior to the sale.

Neither party contested the presumption the property could not be

partitioned without materially impairing its value. KRS 389A.030(3). Combs

insisted on selling the property. By Order entered on May 21, 2021, the property

was referred to the Master Commissioner for sale. The Order stipulated the

property would be sold on July 6, 2021, at 12:00 p.m. local time.

1 Kentucky Revised Statutes.

-3- Pursuant to the court order, the Master Commissioner filed a Notice of

Sale on June 2, 2021, which stated the subject property would be advertised for

two weeks in the Grayson County Record newspaper. The sale of the property was

subsequently advertised in the Grayson County Record on June 24, 2021, and July

1, 2021. When the property was sold at the Master Commissioner sale, Reneer

was the only and highest bidder with a bid of $1.00. It is undisputed Combs did

not attend the sale and did not make any bids herself or through any agent.

Combs then filed a “Notice and Objection to Report of Sale” on July

13, 2021, asking the trial court to set aside the sale, asserting the sale price was so

low compared to the actual value of the property as to shock the conscience of the

court and create a presumption of fraud. On August 23, 2021, the trial court sent

the two feuding parties to mediation. Mediation took place on November 18,

2021, but the parties could not reach an agreement.

Pursuant to the Order entered on March 3, 2022, the trial court denied

Combs’ motion to set aside the sale and confirmed the sale of the subject property.

The trial court found no evidence of fraud or unfairness relating to the sale. After

the parties failed to resolve their disagreement in court-ordered mediation, the trial

court concluded the bid of $1.00 did not shock the conscience in the circumstances,

in part because the bid came from a joint owner who paid all mortgage payments

since 2012.

-4- STANDARD OF REVIEW

We start with the recognition partition or sale of jointly held property

is historically within the equity jurisdiction of the circuit court. See, e.g., Faulkner

v. Terrell, 287 S.W.2d 409 (Ky. 1956). “The circuit court’s decision to confirm or

vacate a judicial sale is reviewed for an abuse of discretion.” U.S. Bank National

Association v. Courtyards University of Kentucky, 594 S.W.3d 205, 209 (Ky. App.

2019) (citations omitted). “The test for abuse of discretion is whether the trial

court’s decision was ‘arbitrary, unreasonable, unfair, or unsupported by sound

legal principles.’” Id. When confirming a sale, the discretion of the trial court

must rest on consideration of all facts and circumstances. Kentucky Joint Land

Bank of Lexington v. Fitzpatrick, 36 S.W.2d 25, 26 (Ky. 1931). Review of the trial

court’s findings of fact shall not be set aside unless they were clearly erroneous.

CR2 52.01. A trial court’s findings of fact are not clearly erroneous if supported by

substantial evidence. Moore v. Asente, 110 S.W.3d 336, 354 (Ky. 2003).

ANALYSIS

Combs argues the accepted bid of $1.00 received in the sale of the

subject property is so grossly inadequate that it alone “shocks the conscience” and

therefore the sale should be set aside. The value of the subject property has been

2 Kentucky Rules of Civil Procedure.

-5- valued at not less than $71,000.00 (the value to which Combs specifically agreed

with Reneer when the joint deed was entered) and as much as $105,000.00.

“Whatever the value of the property, it has long been the rule in this jurisdiction

that mere inadequacy of price is an insufficient ground for setting aside a judicial

sale.” U.S. Bank, 594 S.W.3d at 208 (citations omitted).

“For an inadequate price to require reversal of a judicial sale, the price

in the original sale must be so grossly inadequate as to ‘shock the conscience’ of

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Related

Moore v. Asente
110 S.W.3d 336 (Kentucky Supreme Court, 2003)
Faulkner v. Terrell
287 S.W.2d 409 (Court of Appeals of Kentucky (pre-1976), 1956)
Looper v. Madison Guaranty Savings & Loan Ass'n
729 S.W.2d 156 (Supreme Court of Arkansas, 1987)
Kentucky Joint Land Bank Lexington v. Fitzpatrick
36 S.W.2d 25 (Court of Appeals of Kentucky (pre-1976), 1931)
Gross v. Gross
350 S.W.2d 470 (Court of Appeals of Kentucky, 1961)

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Aletha Carroll Combs v. Karen Reneer, Counsel Stack Legal Research, https://law.counselstack.com/opinion/aletha-carroll-combs-v-karen-reneer-kyctapp-2023.