Estate of Bolen v. Bolen

169 S.W.3d 59, 2005 Ky. App. LEXIS 165, 2005 WL 1704830
CourtCourt of Appeals of Kentucky
DecidedJuly 22, 2005
Docket2004-CA-000382-MR
StatusPublished
Cited by7 cases

This text of 169 S.W.3d 59 (Estate of Bolen v. Bolen) 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
Estate of Bolen v. Bolen, 169 S.W.3d 59, 2005 Ky. App. LEXIS 165, 2005 WL 1704830 (Ky. Ct. App. 2005).

Opinions

OPINION

VANMETER, Judge.

Appellants, Barbara Porter and the Estate of Andy Bolen,2 bring this appeal from an August 8, 2003, judgment of the Knott Circuit Court. We reverse and remand.

In 1994, appellee Jackie Bolen (Jackie) conveyed a plot of land in Knott County, upon which four rental trailers were located, to his sister, Mabel Bolen (Mabel); her husband, Andy Bolen (Andy); and their daughter, Barbara Porter (Barbara). The conveyance was made “with rights of sur-vivorship.”

The transaction was evidenced by three documents prepared by a layperson and dated April 5, 1994. First there was a deed of conveyance, signed by Jackie only, stating a consideration of $25,000 for the land and trailers. Next there was a “CONSIDERATION STATEMENT,” signed by all parties, also reflecting a val[62]*62ue of $25,000.00 for the land and trailers.3 Finally, there was an installment “Sale Contract Agreement,” signed by all parties, providing for the sale of the land and trailers for $55,000. The agreement specifically provided as follows:

To Whom This May Concern:
This sale contract agreement is between Jack Bolen, Hindman, Kentucky and Andy and Mabel Bolen — Barbara A. Porter 2330 St. Lucie Blvd., Fort Pierce, Florida.
This sale agreement is in the total amount of $55,000.00, payable including principal and interest at $500.00 per month or $6,000.00 per year. This contract begins on June 5,1994 and ends on August 5, 2003.
The payments are to be made payable to Jack Bolen and if something should happen that he would decease then the remaining amount would be paid the same way to Phyllis Robinson until the balance is paid; as long as they are still living together at the time of his Jack Bolen’s death. If Phyllis Robinson is not with Jack Bolen at that time, then this sale agreement is paid in full and no remaining balance would be due to any of his descendants.
If at any time the Bolen’s or Ms. Porter decided to sale [sic] then Jack Bolen would have first opposition [sic] of refusal for purchase.
This sale agreement of contract is on the property located beside the Carrie, Kentucky Post Office, recorded in the Knott County Court House, Hindman, Kentucky in record book number 169 and page number 587 dated 5/5/94 [sic].
This contract is signed and agreed upon this 5 day of April 1994.

The deed and the consideration statement were recorded on April 5, 1994, although the sale contract agreement was not recorded until August 27, 1997. While the documents at first glance appear somewhat contradictory, it is apparent from the installment sale contract agreement that the principal amount was $25,000, while the interest payable over the nine year and two month period of the loan totaled $30,000, with the principal and interest payable in equal monthly installments of $500.4

Neither the deed nor the installment sale contract agreement expressly retained a lien upon the property, or contained any provision for default. In fact, neither document contained any reference to the consequences of failing to pay the monthly installments.

On May 1, 1995, Barbara filed a Chapter 7 bankruptcy petition and listed Jackie as a secured creditor.5 The bankruptcy court treated the Knott County transaction as a secured transaction and proceeded accordingly. Upon reviewing Jackie’s claim against Barbara’s undivided one-third sur-vivorship interest in the Kentucky property, the trustee apparently found that the asset was of no benefit to the bankrupt estate and entered an order of abandonment. This removed the Kentucky property from the impact of bankruptcy and permitted Jackie, in the event of default, to proceed against the property in rem.6 [63]*63The bankruptcy court ultimately discharged Barbara from all personal liability.7

Mabel died on April 5, 1999. Andy died on October 7, 2001, after commencement of this action. Barbara therefore was left as the sole owner of the land and trailers by operation of the survivorship deed.

As the payments had fallen into default, Jackie filed an action in the Knott Circuit Court on February 17, 2000, seeking a judgment for the balance due. After the action was amended to assert the equitable claim of reconveyance,8 the circuit court acted within its equitable power and ordered a reconveyance. Barbara brings this appeal.

Barbara argues that the trial court lacked equitable jurisdiction to order re-conveyance of the property. As support, she raises the doctrine of merger, Jackie’s failure to retain a lien, and her discharge in bankruptcy from liability for the debt.

More specifically, Barbara claims that the sale contract agreement merged into the deed of conveyance. While it is well established that prior negotiations will merge into a deed of conveyance,9 here the trial court made the factual finding that the sale contract agreement was not executed prior to the deed of conveyance, and that the parties’ mutual understanding was that the purchase price was to be paid over nine years and two months. The evidence in the record supports the trial court’s finding. Monthly payments provided in the agreement did not commence until two months after the documents were executed and the deed and consideration statement were recorded. Further, the agreement, which refers to the book and page at which the deed was recorded, was not itself recorded until some years after the deed. Clearly, the documents should be interpreted together in determining the parties’ intentions.10 We therefore find no merit in Barbara’s claim of merger.

Next, it is true, of course, that because of her discharge in bankruptcy, Barbara can have no personal liability. However, the trial court clearly erred by concluding that Jackie “was not secured, as he did not file any lien or other security interest with the Knott County Court Clerk’s Office.” Long-standing Kentucky case law is that as between vendor and vendee, a vendor has a hen on granted premises for the unpaid purchase money even if no lien was expressly reserved in the deed.11 So, as regards Barbara, who was a party to the deed and the sales contract, Jackie retained a hen on the property by operation of law for the unpaid purchase price.

Barbara argues that Jackie admitted at the hearing that he had no lien on the property. Jackie’s testimony on this issue, however, was limited to the following ex[64]*64change between Jackie and Barbara’s counsel:

Q: All right. Did they — did Barbara or her father, Andy, or her mother, Mabel, sign a mortgage?
A: No, no mortgage.
Q: And in the deed that I showed you, Exhibit Number 2, is there any language in there saying “I retain a lien on this property?”
A: No, no lien on the property.
Q: All right. And I believe I would be correct to say there is not a lien on the title to those trailers either, is that correct?
A: No, they ain’t no lien on it.

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Estate of Bolen v. Bolen
169 S.W.3d 59 (Court of Appeals of Kentucky, 2005)

Cite This Page — Counsel Stack

Bluebook (online)
169 S.W.3d 59, 2005 Ky. App. LEXIS 165, 2005 WL 1704830, Counsel Stack Legal Research, https://law.counselstack.com/opinion/estate-of-bolen-v-bolen-kyctapp-2005.