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DISTRICT OF COLUMBIA COURT OF APPEALS
Nos. 19-CV-1051 & 20-CV-71
CHARLOTTE R. BLOUNT, APPELLANT,
V.
SQUIRE PADGETT, ET AL., APPELLEES.
Appeals from the Superior Court of the District of Columbia (CAM-1465-14 & CAB-3605-19)
(Hon. William Jackson, Trial Judge)
(Submitted June 23, 2021 Decided October 14, 2021)
Charlotte R. Blount, pro se.
David H. Dupree was on the brief for appellee Eleanor Padgett.
Before GLICKMAN, THOMPSON *, and MCLEESE, Associate Judges.
* Judge Thompson was an Associate Judge of the court at the time of submission. Although her term expired on September 4, 2021, she will continue to serve as an Associate Judge until her successor is confirmed. See D.C. Code § 11- 1502 (2012 Repl.). She was qualified and appointed on October 4, 2021, to perform judicial duties as a Senior Judge and will begin her service as a Senior Judge on a date to be determined after her successor is appointed and qualifies. 2
THOMPSON, Associate Judge: Appellant Charlotte R. Blount appeals from
two rulings of the Superior Court: an October 4, 2019, order denying her request
for a “Determination of Dual Ownership” and for a writ of fieri facias as to the real
property located at 1501 Kalmia Road, N.W. (the “Kalmia Road property”); and an
October 15, 2019, order dismissing as moot her complaint alleging that
defendants/appellees Squire Padgett, Eleanor Padgett, and David Dupree effected a
fraudulent transfer of the Kalmia Road property. 1 We affirm.
I. Factual and Procedural Background
In 2014, appellant Blount brought a legal malpractice action (2014 CA 1465
(hereafter, the “2014 case”) against her former attorneys, Squire Padgett and Lathal
Ponder, seeking damages for their alleged negligence in handling an employment
discrimination lawsuit. In June 2015, Ms. Blount obtained a default judgment
1 Eleanor Padgett filed a brief on behalf of herself and appellee Dupree (Ms. Padgett’s attorney). Appellee Squire Padgett did not file a brief, but Eleanor Padgett’s brief represents that Squire Padgett joins in her brief.
Eleanor Padgett’s brief asserts that Ms. Blount “appeals the denial of her motion to Alter, Amend or Vacate [the] Order Granting [the] Motion to Dismiss[,]” but the Notice of Appeal in No. 20-CV-71 identified only the dismissal order as the order appealed. In any event, our analysis below addresses why the January 14, 2020, order denying Ms. Blount’s Super. Ct. Civ. R. 59(e) motion was correctly decided. 3
against them for over $1 million, a judgment for which they are jointly and
severally liable. After obtaining the judgment, Ms. Blount began efforts to collect
on it. On or about July 15, 2015, she recorded her judgment among the land
records in the District of Columbia Office of the Recorder of Deeds. In addition,
in February 2017, she filed in the land records a Notice of Lis Pendens “against
any sale [o]r transfer of title” of the Kalmia Road property, which was owned by
appellees Squire Padgett and Eleanor Padgett as tenants by the entirety.
The Padgetts, who married in January 1970, acquired the Kalmia Road
property by deed dated September 30, 1975, which conveyed the property to them
as “tenants by the entirety[.]” At the time Ms. Blount filed her lis pendens notice
in February 2017, the Padgetts had been living separate and apart for almost
twenty years. Eleanor Padgett informed the Superior Court that during that time
she “has been solely responsible for mortgage, taxes, repairs and any other
concern, financial or otherwise, related to the property.” In August 2018, after
some delays that they represent related to complications attendant to Squire
Padgett’s tax-lien situation, the Padgetts executed a “Marital Dissolution
Agreement” (the “property settlement agreement”) in anticipation of divorce, and
thereafter filed their petition for absolute divorce on September 4, 2018. Their
property settlement agreement was incorporated in the Judgment of Final Divorce 4
that the Superior Court Family Division entered on September 27, 2018, and that
became final on October 27, 2018. In the property settlement agreement, Squire
Padgett agreed to relinquish all right, title, and interest he had in the Kalmia Road
property and to deed the property to Eleanor Padgett. He executed a warranty deed
conveying that interest on September 27, 2018, the same day the divorce decree
was entered.
As part of her efforts to collect on the malpractice judgment, Ms. Blount
filed in the 2014 case a motion for Determination of Dual Ownership, in which she
sought a writ of fieri facias 2 and a determination that she could attach Squire
Padgett’s share of the Kalmia Road property. Eleanor Padgett moved successfully
to intervene in the post-judgment collection proceedings. 3 For her part, Ms. Blount
2 “A writ of fieri facias is a . . . ‘writ of execution that directs a marshal or sheriff to seize and sell a defendant’s property to satisfy a money judgment.’” Fid. Nat’l Title Ins. Co. of New York v. Tillerson, 2 A.3d 198, 199 n.2 (D.C. 2010) (quoting BLACK’S LAW DICTIONARY 659 (8th ed. 1999)). 3 Ms. Padgett also moved to cancel the “false notice of lis pendens[.]” She argued that the lis pendens notice was improper because the underlying malpractice lawsuit was not related to the property, and because an attempt to collect on a judgment does not create a case related to a defendant’s property that is unrelated to the underlying litigation. See Tillerson, 2 A.3d at 202 (“Actions to recover a debt . . . do not give rise to lis pendens because no specific property is designated for relief in the judgment.” (internal quotation marks omitted)). The Superior Court explained that in any event, “[a] lis pendens doesn’t give you any rights . . . it’s just a notice to third parties[.]” 5
took the additional step of filing a complaint pursuant to D.C. Code § 28-3104
(2012 Repl.), entitled “Verified Complaint for Fraudulent Conveyance of Title,
Concealment to Commit A Fraud, Declaratory Relief to Declare Title in the Names
of Both Parties and to Levy Real Property Located at 1501 Kalmia Road NW,
Washington, DC 20012 and Damages” No. 2019 CA 000075 B (the “2019 case” or
the “2019 complaint”). The Superior Court consolidated the 2019 case with the
2014 (collections) case.
On October 4, 2019, after a series of hearings, the Superior Court denied Ms.
Blount’s motion for a determination of dual ownership, noting that “regardless of
the transfer that took place in late 2018 [in connection with the divorce
proceedings], it is undisputed that when [Ms. Blount] initially attempted to attach
the property in early 2017, [it] was owned by the Padgetts as tenancy by the
entirety.” The court reasoned that Ms. Blount has “a judgment against Squire
Padgett but not Eleanor Padgett,” that “[t]he law is clear that the debt of one
spouse cannot reach . . . property [owned as tenants by the entirety,]” and therefore
that Squire Padgett’s debt to Ms. Blount “is not a joint debt where the property
may be reached by a creditor.” On October 15, 2019, the court entered its order
dismissing the 2019 case as moot, explaining that there were “no outstanding 6
claims remaining . . . due to the resolution of the topic regarding the property in the
principal [i.e., 2014] case.” The instant appeals, which we consolidated, followed.
II. Applicable Law
“The doctrine of tenancy by the entireties[, which] has long been established
in the law of the District of Columbia[,]” “rests on the common law concept of
husband and wife as a single, indivisible unit.” Clark v. Clark, 644 A.2d 449, 450
(D.C. 1994). Tenants by the entireties hold property “in its entirety—without
undivided shares[.]” Id. (quoting 4A RICHARD R. POWELL, THE LAW OF REAL
PROPERTY ¶ 620[3] (1991)). “Although property subject to a tenancy by the
entireties is liable for the spouses’ joint debts and for the individual debts of the
surviving co-tenant, it is unreachable by creditors of one but not of both of the
tenants.” Morrison v. Potter, 764 A.2d 234, 236-37 (D.C. 2000); see also Finley v.
Thomas, 691 A.2d 1163, 1164 (D.C. 1997) (explaining that a tenancy by the
entireties estate is not subject to execution or levy for the debts of only one of the
co-tenants). The tenancy by the entireties doctrine indicates “a preference for
marital community interests over the often competing interests of creditors.”
Benson v. United States, 442 F.2d 1221, 1225 (D.C. Cir. 1971). The “solid” policy
justification is that “the marital relationship is well served by a form of 7
coownership safeguarding marital property from legal hazards which other types
[of tenancy interests] leave as exposures.” In re Wall’s Estate, 440 F.2d 215, 218
(D.C. Cir. 1971). Although the characteristics of a tenancy by the entireties
include “an inability of one spouse to alienate his interest,” Morrison, 764 A.2d at
236, one spouse can voluntarily “relinquish [and convey] his or her interest to the
other.” Clark, 644 A.2d at 452 (citing Am. Wholesale Corp. v. Aronstein, 10 F.2d
991, 992 (D.C. Cir. 1926) (“Aronstein”)).
D.C. Code § 16-910 (2021 Supp.) governs the disposition of tenancy-by-the-
entireties property upon a divorce. It provides that upon the entry of a final decree
of divorce, “in the absence of a valid antenuptial or postnuptial agreement
resolving all issues related to the property of the parties,” the Superior Court shall
“(a) assign to each party his or her sole and separate property” and
(b) value and distribute all other property and debt accumulated during the marriage or domestic partnership that has not been addressed in a valid antenuptial or postnuptial agreement or a decree of legal separation, regardless of whether title is held individually or by the parties in a form of joint tenancy or tenancy by the entireties, in a manner that is equitable, just, and reasonable, after considering all relevant factors, [including, e.g., “each party’s contribution to the acquisition, preservation, appreciation, dissipation, or depreciation in value of the assets which are subject to distribution”]. 8
Id. As its references to an antenuptial agreement or postnuptial agreement
indicate, § 16-910 allows the spouses to enter into an agreement “to deal with their
property as they wish,” Alves v. Alves, 262 A.2d 111, 118 (D.C. 1970), and “to
determine between themselves what was equitable,” Webster v. Walker (In re
Barkats), No. 14-00053, 2020 Bankr. LEXIS 940, at *40 (Bankr. D.D.C. Mar. 31,
2020); see also id. at *5, 37, 40 (rejecting creditor’s argument that upon being
divorced, two ex-spouses each became a 50% owner of the property in question as
tenants in common, because the ex-spouses’ marital settlement agreement, which
divided their interests in the property differently, governed what interests the ex-
spouses had). Likewise, when the court makes a division of property under § 16-
910(b), “[t]he requirement . . . that the court distribute property ‘in a manner that is
equitable, just and reasonable, after considering all relevant factors’ does not mean
that marital property must be divided equally.” Webster v. Hope (In re Hope), 231
B.R. 403, 414 (Bankr. D.D.C. 1999) (citing Burwell v. Burwell, 700 A.2d 219, 223
(D.C. 1997) (“The divorce law contains no presumption in favor of an equal
distribution of property[.]”)); Barbour v. Barbour, 464 A.2d 915, 921 (D.C. 1983)
(same)).
Under § 16-910, the Superior Court must “adjust and apportion property
rights . . . in the same proceeding in which the divorce decree is entered”; thus, title 9
as determined by the court “vests immediately after the divorce in the proper
parties and there is no need for an interim allocation of interests as tenants in
common.” Argent v. Argent, 396 F.2d 695, 698 (D.C. Cir. 1968). 4 Thus, a lien
that cannot attach to property held as tenants by the entireties during a debtor’s
marriage will not necessarily attach to the property upon the debtor’s divorce. 5 Cf.
In re Barkats, 2020 Bankr. LEXIS 940 at *44-46 (concluding that where a marital
settlement agreement, requiring the husband to convey his interest in tenancy-by-
the-entireties property to the wife, was entered into before the divorce took effect
and was incorporated into the judgment of final divorce, the judgment lien held by
the husband’s creditors “only attached to whatever interest [the husband] had in the
4 As we noted in Davis v. Davis, 957 A.2d 576, 579 (D.C. 2008), “[w]e are bound by Argent because it was decided prior to February 1, 1971. See M.A.P. v. Ryan, 285 A.2d 310, 312 (D.C. 1971) (decisions of the United States Court of Appeals for the District of Columbia Circuit prior to February 1, 1971, constitute the case law of the District of Columbia).” Although the D.C. Circuit opined, in a February 12, 1971, post-Argent decision that is not binding on this court, that “[t]he better rule,” and the “majority view in other jurisdictions,” “would seem to be that upon dissolution of the tenancy by the entirety, the parties became tenants in common,” Sebold v. Sebold, 444 F.2d 864, 871 (D.C. Cir. 1971), that is not the immutable rule under District of Columbia law. 5 The law appears to be otherwise in some other jurisdictions. See, e.g., Branch Banking & Trust Co. v. Wright, 328 S.E.2d 840, 842 (N.C. Ct. App. 1985) (“[T]he estate of a tenancy in common of necessity intervenes between absolute divorce and award of title pursuant to equitable distribution when property was held by the entireties[,]” such that “[o]n divorce the lien of the deed of trust upon which plaintiff seeks to recover attached to defendant husband’s one-half undivided interest in the property.”). 10
Property after the divorce,” which was governed by the marital settlement
agreement). This court did say in Travis v. Benson, 360 A.2d 506 (D.C. 1976),
that “[t]he entry of a final divorce decree dissolves the tenancy by the entirety and
converts it into a tenancy in common[,]” leaving the trial court “then authorized to
apportion the property among the parties to the divorce as it sees fit.” Id. at 509.
But the Travis court explicitly recognized that the automatic dissolution of the
tenancy by the entireties “applies only to property in which a tenancy by the
entirety is dissolved by operation of the statute” and thus did not override the
divorcing parties’ agreement pertaining to their property or “affect the general
equitable power” of the court to adjudicate concerning the parties’ respective rights
in property acquired by them during their marriage. Id. at 509 & n.1. 6 Indeed, the
Travis court noted that the D.C. Circuit earlier gave effect to the Travis/Benson
property settlement agreement that “preserve[d] the incidents of the tenancy by the
6 Notably, too, the Travis court was applying the then-current (1967) version of D.C. Code § 16-910, which provided in pertinent part that “[u]pon the entry of a final decree of . . . absolute divorce, in the absence of a valid antenuptial or postnuptial agreement in relation thereto, all property rights . . . in . . . [the] tenancy by the entirety shall stand dissolved, and, in the same proceeding in which the decree is entered, the court may award the property to the one lawfully entitled thereto or apportion it in such manner as seems equitable, just, and reasonable” (emphases added). The statute as it reads currently (and as it read at the time of the Padgetts’ divorce) omits the “tenancy by the entirety shall stand dissolved” language and provides that the court “shall” assign and distribute property in the same proceeding in which the divorce decree is entered. 11
entirety after the divorce,” with the result that, upon the parties’ divorce, “a tax lien
filed against the husband did not attach to property held by the parties as tenants by
the entirety.” Id. at 510 (citing Benson v. United States, 442 F.2d at 1224). 7
The District of Columbia Uniform Fraudulent Transfer Act (“DC UFTA”)
provides in pertinent part that:
(a) A transfer made, or obligation incurred, by a debtor is fraudulent as to a creditor, whether the creditor’s claim arose before or after the transfer was made or the obligation was incurred, if the debtor made the transfer or incurred the obligation:
(1) With actual intent to hinder, delay, or defraud any creditor of the debtor[.]
D.C. Code § 28-3104(a)(1). The term “‘[t]ransfer’ means every mode, direct or
indirect, absolute or conditional, voluntary or involuntary, of disposing of, or
parting with, an asset or an interest in an asset, and includes payment of money,
release, lease, and creation of a lien or other encumbrance.” D.C. Code § 28-
3101(12). The term “‘asset’ means property of a debtor, but does not include . . .
(C) [a]n interest in property held in tenancy by the entireties to the extent it is not
7 In Kleiman v. Kleiman, 633 A.2d 1378 (D.C. 1993), too, this court acknowledged that “the rule in Travis” (about divorce dissolving the tenancy by the entirety and converting it into a tenancy in common) may not apply when property interests are “decreed by the court under the terms of a divorce decree.” Id. at 1381 n.5. 12
subject to process by a creditor holding a claim against only one tenant.” D.C.
Code § 28-3101(2)(C).
III. Analysis
Ms. Blount contends that the Padgetts “became tenants in common [at the
very moment] when they obtained a divorce and attached without merging the
settlement agreement executed [before their divorce] on August 9, 2018[,]” 8 with
the result that Ms. Blount’s “recorded Judgment immediately attached to S.
Padgett’s 50 percent interest in the property.” Ms. Blount argues that the Superior
8 Ms. Blount appears to imply that the fact that the property settlement agreement was not merged in the divorce decree should affect our resolution of the issues. But the incorporation of the property settlement agreement in the divorce decree without merger simply means that the court will enforce the agreement by its terms rather than potentially revise it according to any changed circumstances the parties may claim. Compare Clark v. Clark, 535 A.2d 872, 876 (D.C. 1987) (“A separation agreement which is not merged in the final judgment of divorce is governed by the law of contracts.”), and King v. King, 579 A.2d 659, 662 (D.C. 1990) (quotation marks omitted) (quoting Spencer v. Spencer, 494 A.2d 1279, 1285-86 (D.C. 1985)) (explaining that “our approach to settlement agreements that have not been merged into divorce decrees . . . [is that] the court will leave the parties to continue in their relationship under the agreement”), with Mazza v. Hollis, 947 A.2d 1177, 1179-80 (D.C. 2008) (“[I]f a settlement agreement is merged into the trial court’s order of divorce, . . . the parties’ agreement has been adopted by the court as its own determination of the proper disposition . . . [, and the] court then has discretion to modify its own order based on a showing by either party of a material change in the circumstances[.]”) (internal quotation marks, brackets, and citations omitted). 13
Court “could not rely at all on a tenancy (entirety) that did not exist on October 4,
2019 to deny Blount’s Motion for Determination of Dual Ownership.”
We disagree. Ms. Blount’s judgment lien, which she seems to acknowledge
did not attach to the Kalmia Road property while it was held by the Padgetts as
tenants by the entireties, did not automatically attach to Squire Padgett’s “share” of
the property upon the divorce, because Squire Padgett had no such share. The
divorce decree distributed the Padgetts’ tenancy-by-the-entireties property by
incorporating the Padgetts’ written agreement that Squire Padgett would convey
his interest in the Kalmia Road property to Eleanor Padgett upon the divorce.
Squire Padgett executed a warranty deed accomplishing precisely that on the same
day the divorce decree was entered, such that there was no interim or intervening
period when the Padgetts’ tenancy by the entireties became a tenancy in common
that allowed the judgment lien to attach to Squire Padgett’s divided share of the
property. The status of the Kalmia Road property at the time the Superior Court
denied Ms. Blount’s motion for a determination of dual ownership was that the
property was owned solely by Eleanor Padgett, as resolved by the Padgetts’
property settlement agreement, the divorce decree, and the warranty deed. 9
9 Even in the absence of the Padgetts’ property settlement agreement, it seems likely that the court would have assigned the Kalmia Road property to (continued…) 14
Accordingly, the Superior Court did not err in denying Ms. Blount’s motion for a
determination that the property was dually owned by Squire Padgett and Eleanor
Padgett. Cf. Clark, 644 A.2d at 453 (conveyance by husband to wife of his interest
extinguished his interest in the tenancy-by-the-entirety property); In re Barkats,
2020 Bankr. LEXIS 940, at *44-46 (divorce decree incorporating property
settlement agreement governed what interest ex-husband had in property and
whether there was any interest for his creditors to attach).
Ms. Blount emphasizes that appellees “voluntarily changed the tenancy by
entirety during the collections case” in response to her Notice of Lis Pendens and
failed to notify the collections court about the Padgetts’ property settlement
agreement and divorce until Ms. Blount learned of and disclosed the same. 10 She
further asserts that appellees “maneuvered” and “deliberately conspired to commit
a fraud by removing the asset out of S. Padgett’s name and therefore out of the
(…continued) Eleanor Padgett, who represented to the court (without dispute) that she had lived there without Squire Padgett for over twenty years, paid the mortgage and taxes and paid for all the maintenance and upkeep during that period, all without contributions from Squire Padgett. 10 We note that the Superior Court judge was very troubled by these omissions, but found it “unclear what remedy is being sought by the plaintiff for this claim” and reasoned, in his order denying the Rule 59(e) motion, that Ms. Blount had failed to state a claim. 15
reach of Blount as the judgment creditor.” Challenging the dismissal of her 2019
complaint, Ms. Blount further argues that the claims in her complaint “are
sufficiently different and unrelated to the issue of the determination of dual
ownership” that they were not mooted or barred by the ruling on the dual
ownership motion.
Mootness may not have been the most precise shorthand for the Superior
Court’s reasoning in dismissing the 2019 case (reasoning the court set out in
greater detail in its order denying Ms. Blount’s Rule 59(e) motion), but the
dismissal was not in error. There is no dispute that, prior to the conveyance
required by the divorce decree and for many years before Ms. Blount obtained her
judgment, the Kalmia Road property was tenancy-by-the-entireties property. Thus,
by definition, and as the Superior Court found in denying the Rule 59(e) motion,
the Kalmia Road property was not an “asset” of the debtor Squire Padgett that
could be the subject of a “transfer” that was fraudulent within the meaning of the
DC UFTA. See § 28-3101(2)(C) and (12) and § 3104(a)(1). 11 Further, as the case
law discussed in section II above establishes, as a matter of law Squire Padgett’s
11 Cf. Estes v. Titus, 751 N.W.2d 493, 498 (Mich. 2008) (“[I]t is difficult to comprehend how disposing of property that a creditor cannot reach [such as property held as tenants by the entirety] could ‘defraud’ that creditor.”). 16
conveyance of his interest in the Kalmia Road property to Eleanor Padgett did not
hinder or delay Ms. Blount’s rights as a creditor for purposes of the DC UFTA,
because Ms. Blount at no time had a right to attach the Kalmia Road property. See
Aronstein, 10 F.2d at 992 (holding that where real property was conveyed to
Aronstein and his wife as tenants by the entireties, Aronstein subsequently became
indebted to appellant creditors, and Aronstein thereafter conveyed to his wife his
interest in the real estate, the creditors “were not entitled to subject the separate
interest of Aronstein to the payment of their claims” and that “[h]is conveyance to
his wife . . . could not hinder or delay them in the collection of their judgments”);
accord District-Realty Title Ins. Corp. v. Forman, 518 A.2d 1004, 1009 (D.C.
1986) (reasoning that creditor “could not have detrimentally relied on [tenancy-by-
the-entireties] assets when it extended credit to Mr. Forman since it already knew
that they were no longer available to him” and “therefore cannot now claim that it
was hindered or defrauded by their transfer to Sallie Forman”); see also Jensen v.
Anderson (In re Anderson), 561 B.R. 230, 243 (Bankr. M.D. Fla. 2016) (holding
that a transfer of District of Columbia tenancy-by-the-entireties property held by a
debtor and his wife to a trust in the wife’s name was not subject to avoidance as a
fraudulent transfer); Estes, 751 N.W.2d at 498 (explaining that under the Michigan 17
UFTA, property held by spouses as tenants by the entirety is not an asset, and “its
distribution pursuant to the divorce judgment is not a transfer”). 12
In short, the 2019 complaint failed to state a claim for fraudulent transfer
under the DC UFTA. There being no fraudulent transfer, we also discern no error
in the Superior Court’s reasoning that the complaint failed to make out the
elements of civil conspiracy, which include, inter alia, an agreement “to participate
in an unlawful act, or in a lawful act in an unlawful manner.” Exec. Sandwich
Shoppe, Inc. v. Carr Realty Corp., 749 A.2d 724, 738 (D.C. 2000). 13
12 We note that a different rule might apply under the fraudulent transfer provisions of the federal Bankruptcy Code. See In re Hope, 231 B.R. at 415-16 (explaining that an avoidable, “fraudulent conveyance [under 11 U.S.C. 548(a)] may exist if the debtor agreed to the nondebtor spouse’s receiving more than any rational application of the factors [listed in § 16-910] would have yielded had the matter been litigated”); id. at 420 (“A property settlement approved by a divorce decree can be avoided as fraudulent under 11 U.S.C. §§ 548(a)(1) or (2)[.]”). But those provisions are inapposite in this case. 13 Nor did the complaint state a general claim for fraud (by concealment of information from the court), because it fails to allege the elements of fraud: (1) a false representation, (2) with reference to a material fact, (3) made with knowledge of its falsity, (4) made with the intent to deceive and (5) action taken in reliance on the representation. Fort Lincoln Civic Ass’n, Inc. v. Fort Lincoln New Town Corp., 944 A.2d 1055, 1073 n.22 (D.C. 2008). Again, Ms. Blount argues that the concealment was appellees’ failure to tell the collections court (until forced to do so by Ms. Blount’s disclosure) that the Padgetts were divorced and no longer held the Kalmia Road property as tenants by the entireties and failure to tell the divorce court about Ms. Blount’s recorded judgment against Squire Padgett and her notice of lis pendens regarding the Kalmia Road property. Given that it is District of (continued…) 18
For the foregoing reasons, the judgment of the Superior Court is
Affirmed.
(…continued) Columbia law pertaining to tenancies by the entireties and the distribution of marital property that govern and that have foreclosed Ms. Blount’s efforts to attach a lien to the Kalmia Road property, we cannot discern any injury to Ms. Blount from appellees’ having not been forthcoming at the outset about the foregoing circumstances (even assuming that their actions entailed false representations regarding a material fact with intent to deceive).