Alexander v. Cobb

CourtSupreme Court of Virginia
DecidedFebruary 27, 2020
Docket181613
StatusPublished

This text of Alexander v. Cobb (Alexander v. Cobb) is published on Counsel Stack Legal Research, covering Supreme Court of Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Alexander v. Cobb, (Va. 2020).

Opinion

PRESENT: All the Justices

LINDA LEE ALEXANDER OPINION BY v. Record No. 181613 JUSTICE S. BERNARD GOODWYN February 27, 2020 DAVID COBB

FROM THE CIRCUIT COURT OF BATH COUNTY John E. Wetsel, Jr., Judge

In this appeal, we consider whether the circuit court erred in concluding that a prior final

circuit court order had a preclusive effect on a party’s claims regarding her ownership rights in

parcels of real property.

BACKGROUND

George Cobb (George) and Dorothy Cobb (Dorothy), husband and wife, owned three

tracts of land in Bath and Highland counties, Virginia (the Properties), as tenants in common.

George and Dorothy each owned an undivided one-half interest in the Properties in fee simple

absolute.

George died testate on April 7, 2003. George was survived by his wife, Dorothy, and

their two children, Linda Lee Alexander (Linda) and David Cobb (David).

George’s will, as it relates to the distribution of the relevant real property, stated the

following:

Real Estate. I give to my wife, if she survives me, a life estate in all of my real property or interest in real property which I own at the time of my death. I give the remainder interest in such property (or all of such property if my wife does not survive me) to my descendants who survive me, per stirpes.

I authorize my wife to sell, convey, transfer, and execute all assurances of title to any real estate passing to her for life under this Article of this Will . . . . I authorize my wife to invest the net proceeds of sale in such securities or other property as she, in her uncontrolled discretion, may wish, and I do not limit her to investments authorized for fiduciaries in Virginia. All that I require of her is that the investment, in whatever form it is made, shall be shown as belonging to the

1 life estate here given to her. I further authorize my wife to apply and expend whatever portion of the principal of the proceeds of sale of such real estate as might be necessary and proper for her support, maintenance and health.

Sometime after George’s death, Dorothy, due to her age and deteriorating health, began

living with Linda. On May 5, 2009, and March 23, 2010, Dorothy executed deeds of gift

purporting to convey the Properties to Linda in fee simple.

David subsequently filed a complaint in the Circuit Court of the City of Alexandria

against Dorothy and Linda alleging, among other things, a fraudulent conveyance. He requested

that the deeds of gift from Dorothy to Linda be declared void, as they concerned the remainder

fee simple interest in the life estates that Dorothy acquired through her husband’s will. On May

2, 2011, the Alexandria Circuit Court held a bench trial. The Alexandria Circuit Court initially

ruled, from the bench, in favor of Dorothy and Linda. However, the court, sua sponte,

reconsidered and reversed its bench ruling because it concluded that Dorothy had not followed

the requirements of George’s will concerning the disposition of the life estates Dorothy inherited.

On October 27, 2011, the Alexandria Circuit Court entered an order consistent with its new

ruling (the 2011 Order), awarding judgment for David on his fraudulent conveyance claim and

voiding the purported fee simple conveyances of the Properties from Dorothy to Linda.

On October 18, 2012, Dorothy executed deeds of sale regarding the Properties. The

deeds stated that Dorothy conveyed the undivided one-half interest she possessed in the

Properties, as well as the “undivided one-half interest held by Dorothy P. Cobb, as a life tenant

with a power of sale” to Linda.

On May 8, 2014, Dorothy and Linda filed a complaint against David in the Circuit Court

of Bath County. 1 The complaint sought to have the circuit court (1) interpret George’s will in a

1 Dorothy and Linda also filed a complaint against David in the Circuit Court of Highland County. The proceedings were consolidated in Bath County Circuit Court.

2 way that authorized Dorothy to “dispose of the life estate” she had in the Properties, (2) quiet

title to the Properties in Linda, and (3) confirm the 2012 deeds of sale as “good fee simple

deeds” which vested complete fee simple ownership of the Properties in Linda.

In response, David filed a special plea in bar, arguing that collateral estoppel barred the

relief requested in the complaint because the Alexandria Circuit Court had “already ruled that

Dorothy Cobb does not have the authority under the Will to sell anything but her life estate, and

the sale of the life estate has further restriction and requirements upon it.” He asserted that the

2012 deeds of sale could not and did not convey complete fee simple ownership of the property

in which Dorothy only had a life estate interest. 2

On July 17, 2015, the Bath County Circuit Court referred the matter to a commissioner in

chancery for her to take evidence as well as to make factual and legal determinations. After

holding an evidentiary hearing, the Commissioner filed a report with the circuit court on October

7, 2015. The Commissioner found that the 2011 Order held that Dorothy could only convey her

life estates and not the remainder interest in the 50% of the Properties that was willed by George.

Thus, the Commissioner concluded that the gravamen of the relief requested in Dorothy and

Linda’s complaint, a determination that the deeds of sale from Dorothy conveyed 100% fee

simple ownership of the Properties to Linda, was barred by collateral estoppel.

On December 11, 2015, the Bath County Circuit Court entered a final decree (the 2015

Final Decree) that incorporated the Commissioner’s report, sustained David’s plea of collateral

estoppel, and dismissed, with prejudice, Dorothy and Linda’s complaint, which claimed that

2 The parties do not dispute that Dorothy could and did validly convey her 50% fee simple interest in the Properties to Linda. The dispute concerns fee simple ownership of the 50% interest in the Properties that George held at the time of his death.

3 Linda had complete fee simple ownership of the Properties because of the 2012 deeds of sale

from Dorothy. The 2015 Final Decree was not appealed.

Dorothy died on April 23, 2017.

On October 2, 2017, David filed a complaint in the Bath County Circuit Court against

Linda seeking an accounting of the rents and profits from the Properties, requesting a partition of

sale of the Properties, and pleading claims of ejectment and conversion. David asserts that he

has a 25% interest in the Properties (half of the fee simple remainder from George’s half of the

Properties) as a tenant in common with Linda. On November 17, 2017, Linda filed an answer

admitting most of the facts, but denying David’s characterizations of the 2011 Order and 2015

Final Decree, and denying that David had any interest in the Properties.

On August 22, 2018, Linda filed an additional responsive pleading that she labelled as a

motion for declaratory judgment. It asked the Bath County Circuit Court to quiet title to the

Properties in her. In that pleading, she claimed 100% ownership of the Properties based upon the

2012 deeds of sale she received from Dorothy. She argued that the 2011 Order authorized

Dorothy to sell the Properties, and contends that the 2011 Order is binding as to the ownership of

the Properties under the law of the case doctrine.

On September 11, 2018, the Bath County Circuit Court held a bench trial. The circuit

court noted that it was “constrained” by the 2015 Final Decree.

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Alexander v. Cobb, Counsel Stack Legal Research, https://law.counselstack.com/opinion/alexander-v-cobb-va-2020.