Estate of Baker v. Lahrman

505 N.E.2d 104, 1987 Ind. App. LEXIS 2464
CourtIndiana Court of Appeals
DecidedMarch 19, 1987
DocketNo. 76A04-8608-CV-241
StatusPublished
Cited by7 cases

This text of 505 N.E.2d 104 (Estate of Baker v. Lahrman) is published on Counsel Stack Legal Research, covering Indiana Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Estate of Baker v. Lahrman, 505 N.E.2d 104, 1987 Ind. App. LEXIS 2464 (Ind. Ct. App. 1987).

Opinion

YOUNG, Judge.

Mary L. Gunning and her children appeal the entry of summary judgment in favor of Donald and Noreta Lahrman in a suit for specific performance of a real estate contract. The only issue raised by this appeal is whether notice to the attorney for the personal representative of an estate is sufficient to exercise a real estate option which was granted by the decedent prior to his death. We affirm.

On March 16, 1983, Donald and Noreta Lahrman acquired an option to purchase real estate from James G. Baker. Pertinent paragraphs of the option stated:

1. Unless exercised prior thereto, this Option shall expire on the 15th day of March, 1985, at 12:00 noon, Eastern Standard Time.
2. Buyers may exercise the Option by giving notice to the Seller before the expiration of the Option. Notice shall be deemed to be given if in writing and either delivered in person to the Seller or deposited in the United States Mails, certified or registered, first class postage prepaid and addressed to the Seller at his address set forth above, and bearing a postmark prior to the expiration time, and accompanied by Ten Thousand ($10,-000.00) earnest money.
8. This agreement shall be binding upon and inure to the benefit of the respective heirs, personal representatives and assigns of Sellers and of Buyers.

[105]*105James Baker died prior to the expiration of the option. His will was admitted to probate on October 18, 1984 and personal representative letters were issued to Mary L. Gunning, Baker's daughter. Gunning and her adult children apparently were dev-isees under Baker's will as well as his heirs-at-law.1 The Lahrmans did not file a "claim" 2 against Baker's estate but made several unsuccessful attempts to serve notice of the exercise upon Gunning. On March 11, 1985, after learning that Gunning would be out of town until after the option expired, the Lahrmans gave a written "Notice of Intention to Exercise Rights Under Real Estate Option Agreement" and a $10,000.00 cashier's check payable to the "James G. Baker Estate" to the estate's attorney.3

On March 19, 1985, the Lahrmans were notified that Gunning and her children refused to sell the real estate. The Lahrmans brought suit for specific performance against the estate and Gunning and her children. Although the trial court dismissed the complaint as to the estate,4 it entered summary judgment in favor of the Lahrmans, finding that notice to the estate's attorney was sufficient to exercise the option.

Gunning and her children argue that the option was not properly exercised because notice should have been given directly to them rather than to the estate's attorney. In support of this contention, they strongly rely upon IND.CODE 29-1-7-28 and Demma v. Forbes Lumber Co. (1962), 133 Ind.App. 204, 181 N.E.2d 253.5 IC 29-1-7-23 provides that title to property passes immediately to the distributees upon the decedent's death. In Demma, the First District held that because title to a decedent's property is held by the distributees, they are [106]*106necessary parties to a suit to foreclose a mechanic's lien. 'The fact that distributees are titleholders and are therefore necessary parties, however, does not necessarily lead to the conclusion that they must receive notice of the exercise of an option to purchase real estate. In fact, if the me-chanie's lien situation is analogous, it suggests the opposite conclusion.

Before bringing suit for specific performance, the optionee must give notice of the exercise. Similarly, before bringing suit to foreclose, a mechanic's lien claimant must file notice of his intent to hold a lien. IND. CODE 32-8-3-3. In the mechanic's lien situation, the notice is sufficient if it substantially names the owner as set forth in the latest entry in the county auditor's transfer book. Id. Until the estate is distributed, the transfer book will reflect the decedent as the owner. Hence, the notice may not be filed in the names of the dis-tributees. It is unlikely that the county recorder will send notice to the distributees because notice will be mailed to the address of the owner as shown on the property tax records. Id. Until the estate is closed, the property tax records will reflect the decedent's address. Notice of a lien which was in the name of the decedent has been held sufficient even though his distributees were titleholders. Riverside Fixture Co. v. Quigley (1912), 35 Nev. 17, 126 P. 545. Notice in the name of the estate or personal representative also has been held sufficient. See 48 A.L.R.3rd 153 and cases cited therein. A distributee therefore may not receive notice of an act which is required prior to bringing suit even though he may be a necessary party to the suit.

It would be unfair to require a real estate optionee to give notice of the exercise directly to the distributees. One problem with such a requirement is the fact that while title passes immediately, to whom it passes and the interest which passes remains undetermined until the estate is closed. IND.CODE 29-1-17-2(b) provides in part:

In its decree of final distribution, the court shall designate the persons to whom final distribution is to be made, and the proportions or parts of the estate, or the amounts, to which each is entitled under the will and the provisions of the probate code....

Additionally, IND.CODE 29-1~17-2(d) provides in part:

The decree of final distribution shall be a conclusive determination of the persons who are successors in interest to the estate of the decedent and of the extent and character of the interest therein....

Because the judicial determination of to whom title has passed and the interest which has passed does not occur until final distribution,6 the optionee will not know who is to receive notice of the exercise until the final decree is entered.

At oral argument, Gunning and her children's attorney suggested that the optionee could locate the names and addresses of the distributees through the petition for probate. While this information is required on the petition, it is only required "so far as such are known or can with reasonable diligence be ascertained by the personal representative." IND.CODE 29-1-7-5(2). The optionee therefore can not rely on the petition to give him the correct names and addresses of distributees. A complete and correct list of distributees is not available until the court determines the identity of the distributees and enters its final decree of distribution. IC 29-1-17-2(d).

Assuming an optionee could correctly predict whom the court will designate as distributees and where to locate them, the [107]*107question remains as to who is to receive any earnest money when it is required in connection with the exercise of the option. It was suggested at oral argument that the check list all of the distributees. This solution, however, is impractical, puts the op-tionee's funds at risk, and violates the personal representative's statutory right to possession of estate property.

In a large estate, there may be numerous distributees, making it impractical to list each as a payee. Even if all the distributees could be listed, giving the check directly to the distributees puts the optionee's funds at risk.

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Bluebook (online)
505 N.E.2d 104, 1987 Ind. App. LEXIS 2464, Counsel Stack Legal Research, https://law.counselstack.com/opinion/estate-of-baker-v-lahrman-indctapp-1987.