Bell v. Singletary

35 Pa. D. & C.5th 278
CourtPennsylvania Court of Common Pleas, Monroe County
DecidedJanuary 8, 2014
DocketNo. 8026 CIVIL 2013
StatusPublished

This text of 35 Pa. D. & C.5th 278 (Bell v. Singletary) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Monroe County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bell v. Singletary, 35 Pa. D. & C.5th 278 (Pa. Super. Ct. 2014).

Opinion

WILLIAMSON, J.,

This matter comes before the court on defendant Citizens Bank of Pennsylvania’s preliminary objections to plaintiff’s complaint. Defendant contends plaintiff’s complaint is legally insufficient and lacks specificity.

This case arises out of a deed executed in favor of defendant Singletary by the decedent, Ollie Johnson, Sr., a will and codicil of Ollie Johnson, Sr., and a note and mortgage executed by Singletary after the death of the decedent. The following is a timeline of events as set forth in plaintiffs complaint:

June 3, 1998 — Ollie Johnson, Sr. (decedent) executes a Last Will and Testament leaving his entire Estate equally to his five (5) children, including defendant Singletary and the executrix bell.
December 23, 1998 — Decedent executes a deed conveying a one-half interest he had in property known as Lot 1762 section H, Pocono Farms, Coolbaugh Township, Monroe County, Pennsylvania to defendant Singletary.
January 12, 1999 — the deed is recorded.
April 1, 1999 — Decedent executed a Codicil wherein he named defendant Singletary as beneficiary of a one-[280]*280half interest in the Lot 1762 Sec. H Pocono Farms property (real property) and all personal property to go equally to all of his children.
October 18, 2004 — Decedent dies.
March 16, 2007 — Defendant Singletary executes a note and mortgage in favor of defendant Citizens bank of Pennsylvania with the mortgage encumbering the Lot 1762 Sec. H. Pocono Farms property as collateral.
June 5, 2007 the mortgage is recorded.
November 4, 2011 — Plaintiff is granted letters of testamentary for the Estate of Ollie Johnson, Sr.
September 16, 2013 —Plaintiff files this suit.

Plaintiff contends in her complaint that defendant Singletary only had a one-half interest in the real property at the time she executed the note and mortgage and the estate retained the other one-half interest. Plaintiff states defendant had no authority from the estate to encumber the one-half interest ofthe estate with the mortgage to Citizens. Plaintiff alleges defendant Singletary misappropriated estate property, committed fraud, and was unjustly enriched. Plaintiff also raised claims against Citizens Bank of Pennsylvania, and a John Doe Title Insurance Company that closed on the loan. Plaintiff alleges Citizens Bank engaged in fraud and misappropriation with defendant Singletary, with regard to the note and mortgage.

Citizens has raised in their preliminary objections that the undisputed allegations of plaintiff’s complaint show Singletary was the sole owner of the real property at the time of execution of the note and mortgage, and that plaintiff failed to raise an estate within one year of the [281]*281decedent’s death. Citizens argues that as a result, plaintiff’s claims are barred, and they are entitled to a demurrer.

Citizen’s preliminary objections are based upon insufficient specificity in the complaint under Pa. R.C.P. 1028 (a)(3) and legal insufficiency under Pa. R.C.P. 1028 (a)(4). In reviewing preliminary objections, the court must rely on the facts as solely derived from the complaint. BiltRite Contractors, Inc. v. The Architectural Studio, 581 Pa. 454, 866 A.2d 270 (2005). The court must accept all well-pleaded facts from the complaint, and if those facts fail to support a claim upon which relief can be granted, preliminary objections in the nature of a demurrer shall be sustained. Connor v. Archdiocese of Philadelphia, 601 Pa. 577 (2009); Sunbeam Corp. v. Liberty Mutual Ins. Co., 781 A.2d 1185 (Pa. 2001). The preliminaiy objections cannot be based on facts outside of the complaint, or they will be dismissed as a “speaking demurrer.” Martin v. Dept. of Transp., 556 A.2d 969 (Pa. Cmwlth. 1989).

A pleading is insufficiently specific if it is not sufficiently clear to enable a party to prepare a defense. See Estate of Swift v. Northeastern Hosp. of Philadelphia, 456 Pa. Super. 330, 690 A.2d 719 (1997). Defendant alleges the complaint is insufficiently specific. We find the reasons set forth by citizens for insufficient specificity are more adequately addressed in their objection for legal insufficiency.

Plaintiff claims defendant Singletary had at the time of the decedent’s death, at most, a one-half interest in common with decedent in the real property. A party who owns an interest in real estate as a tenant in common, owns a separate and distinct undivided title, in which they have the full legal authority, without the need for [282]*282consent from any other tenant in common, to encumber, or even sell, that one-half interest. See In re Estate of Quick, 588 Pa. 485, 905 A.2d 471 (2006); In re Sale of Property of Dalessio, 657 A.2d 1386 (Pa. Cmwlth. 1995), citing Werner v. Quality Service Oil Co., Inc., 337 Pa. Super. 264, 486 A.2d 1009 (1984); accord, United States v. Craft, 535 U.S. 274, 122 S. Ct. 1414 (2002) (noting that even under English Common Law, it has always been the case that tenants in common may unilaterally sell, gift or encumber their shares therein). It is well settled that each tenant in common may convey, encumber or devise his or her undivided interest in real property. See Ladner Pennsylvania Real Estate Law, Section 8.03, p. 8-6 (Bisel 5th ed. 2006).

The complaint contains allegations and a deed attached as an exhibit, clearly indicating that defendant Singletary had at least a one-half interest as tenant in common with the decedent at the time of the decedent’s death. The complaint alleges that almost three years after the decedent’s death, Singletary signed the note and mortgage. Singletary clearly had at least a one-half interest that could be encumbered at that time. She had at least a one-half interest as tenant in common from the 1998 deed. Therefore, based on plaintiff’s own undisputed factual allegations, Singletary had a one-half interest that she could encumber with the mortgage. The mortgage encumbering the property, as executed by Singletary, would only have legal effect on whatever interest she had in the property, since only she executed the mortgage. See Ladner on Pennsylvania Real Estate Law, supra. This by itself is enough for plaintiff’s claims to fail to support a cause of action. The note signed by Singletary had no effect on the plaintiff. It effected Singletary only. The [283]*283mortgage was only secured on Singletary’s portion of the interest, which interest, as a tenant in common, could be encumbered.

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Related

United States v. Craft
535 U.S. 274 (Supreme Court, 2002)
Bilt-Rite Contractors, Inc. v. Architectural Studio
866 A.2d 270 (Supreme Court of Pennsylvania, 2005)
Rohm & Haas Co. v. Continental Casualty Co.
781 A.2d 1172 (Supreme Court of Pennsylvania, 2001)
Connor v. Archdiocese of Philadelphia
975 A.2d 1084 (Supreme Court of Pennsylvania, 2009)
Estate of Swift Ex Rel. Swift v. Northeastern Hospital of Philadelphia
690 A.2d 719 (Superior Court of Pennsylvania, 1997)
Martin v. Commonwealth
556 A.2d 969 (Commonwealth Court of Pennsylvania, 1989)
In Re Estate of Quick
905 A.2d 471 (Supreme Court of Pennsylvania, 2006)
Werner v. Quality Service Oil Co., Inc.
486 A.2d 1009 (Supreme Court of Pennsylvania, 1984)
In re Estate of Peterson
649 A.2d 1007 (Commonwealth Court of Pennsylvania, 1994)
In re Sale of Property of Dalessio
657 A.2d 1386 (Commonwealth Court of Pennsylvania, 1995)

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Bluebook (online)
35 Pa. D. & C.5th 278, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bell-v-singletary-pactcomplmonroe-2014.