Helen Sanders v. Colleen Gould

CourtMissouri Court of Appeals
DecidedJanuary 16, 2024
DocketED110814
StatusPublished

This text of Helen Sanders v. Colleen Gould (Helen Sanders v. Colleen Gould) is published on Counsel Stack Legal Research, covering Missouri Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Helen Sanders v. Colleen Gould, (Mo. Ct. App. 2024).

Opinion

In the Missouri Court of Appeals Eastern District DIVISION TWO

HELEN SANDERS, ) No. ED110814 ) Respondent, ) Appeal from the Circuit Court ) of St. Louis County vs. ) ) Honorable Kristine A. Kerr COLLEEN GOULD, ) ) Appellant. ) FILED: January 16, 2024

Introduction

This appeal arises from a dispute between two sisters over the purchase of a house. Helen

Sanders alleged that her sister, Colleen Gould, promised her she would co-sign a loan so that

Sanders could buy a house for her family. According to Sanders, instead of simply co-signing the

loan, Gould purchased the house in Gould’s name only and then told Sanders that she and her

family could live there and make payments toward the mortgage. Sanders claimed that Gould

promised to transfer title to Sanders when Sanders was more financially stable. After years of

Sanders paying toward the mortgage and making improvements to the house, Gould refused to

transfer title to Sanders.

Sanders sued Gould for fraudulent misrepresentation and sought damages based on the

amount of money she had put into the house in mortgage payments and improvements. A jury

found in favor of Sanders and awarded her damages. Gould appeals the verdict as to liability, claiming there was insufficient evidence to support the falsity and reasonable reliance elements of

fraudulent misrepresentation. We disagree and affirm the judgment entered on the jury’s verdict.

After the jury trial, the trial court entered judgment on Sanders’s alternative request for a

constructive trust, ordering Gould to sell the house to Sanders. Gould appeals that judgment on

the ground that it results in a double recovery to Sanders, allowing her to receive title to the house

in addition to the damages awarded by the jury. We agree and reverse the constructive trust

judgment.

Factual and Procedural Background

Sanders was looking for a house to buy for her family. Sanders’s and Gould’s mother

planned to loan Sanders money for a down payment. After many months, Sanders found a house

that she was interested in buying, at which point Gould got involved in the matter. Sanders testified

that Gould tried “to sell [Sanders] on the idea of [Gould] getting a mortgage in her name because

her credit was better than [Sanders’s] at the time.” Gould also touted that she was “very smart”

and had experience buying a house, whereas Sanders would be “confused” and “taken advantage

of” without Gould’s help. Sanders agreed that Gould should co-sign the loan for the house.

Sanders understood that, as co-signors, both she and Gould would be on the title of the house,

which was something she and Gould had discussed many times. But Gould did not honor that

arrangement. Instead, without informing Sanders, Gould signed the mortgage loan and purchased

the house in her name only, using a $21,000 loan she obtained from their mother for the down

payment. Sanders learned this a week or two later and was “furious.” She told Gould that she

would not move into the house unless her own name was on the title. Gould responded by

convincing Sanders that she had no choice but to live in the house because their mother would not

loan her more money to buy another house. Sanders also believed it was unlikely she would find

2 another house for the right price. Gould dismissed Sanders’s concerns about not having her name

on the title and told her that Gould considered this to be Sanders’s house. Sanders explained at

trial:

[Gould] said that the house is mine, I was being ridiculous. She was my sister I could trust her, and that the house was mine, not to worry. Oh, I’m being ridiculous I should calm down. Of course the house is mine and me and the kids and, you know, my husband would all be happy there. In later testimony, Sanders again described how Gould reassured her:

[D]on’t worry about it, I will sign it over to you. We will add your name. You will be okay. I won’t screw you over, it will be all right, you should move in. We’ll give you the house just make all the payments, the house is yours. It’s your house it’s not my house, why would I need two houses? It’s your house.

Sanders testified that Gould specifically represented that “she would have [Sanders] get

the house when [Sanders] was in a better financial state,” which, according to Sanders, meant when

she was “earning more money.” Sanders testified that she relied on this representation when she

began living in the house and making payments to Gould for the mortgage. When Sanders was

asked why she relied on that representation after how Gould had handled the purchase of the house,

Sanders explained:

Because [Gould] led me to believe that she would put the house in my name when I was able to get financing. She . . . understood it was my house, and that if I paid all the mortgage, the tax, and the insurance that it, you know, yes, of course it was my house. In fact, she would say of course it’s your house. And I even said why— you know, she doesn’t need two houses, my mother would never [buy] two houses for her and none for me.

At trial, Gould denied promising to transfer title to Sanders, claiming instead that she told

Sanders she could buy the house from her when Sanders was able to secure her own financing.

Gould repeatedly testified that her intent was for Sanders to “actually buy the house” when she

was financially able to do so.

3 The house was not livable at the time Gould bought it, and Sanders paid for the repairs

needed to obtain an occupancy permit. Sanders testified that she and her family moved into the

house in the spring of 2009 and continued to make repairs and improvements. Years later, Sanders

asked Gould for documentation to prove that Sanders was living in the house and paying Gould

for the mortgage because Sanders needed that information to apply for certain government

benefits. In response, Gould presented Sanders with a two-year lease backdated to December 15,

2008, which Sanders signed even though Gould would not correct the date.

In 2017, Sanders’s income doubled and she informed Gould she was in a “better financial

position” and was ready to take over the mortgage and title to the house. After Gould refused,

Sanders filed this lawsuit in June 2017. The amended petition alleged that Gould fraudulently

misrepresented that “once [Sanders] had a more stable financial situation, [Gould] would transfer

the title and mortgage to [Sanders].” Gould filed a motion for judgment on the pleadings, arguing

that the representation was too vague as a matter of law to be actionable. The trial court denied

the motion, and the case proceeded to a jury trial in November 2021. At trial, Sanders sought

damages to compensate her for the $55,000 in monthly payments she had made to Gould over the

years, the $38,000 in repairs and improvements, and the $21,000 her mother loaned to Gould but

wanted Sanders to have. The jury found in favor of Sanders as to her fraudulent misrepresentation

claim and awarded her $95,000 in damages.

Gould also filed a claim for unpaid rent against Sanders based on the written lease, which

was consolidated with and tried at the same time as Sanders’s fraudulent misrepresentation claim.

Sanders and her family still lived in the house at the time of trial, and she acknowledged that Gould

had not accepted a payment from her since May 2017. The jury found in favor of Gould on this

claim, awarding her $30,000 in damages for unpaid rent.

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Helen Sanders v. Colleen Gould, Counsel Stack Legal Research, https://law.counselstack.com/opinion/helen-sanders-v-colleen-gould-moctapp-2024.