Moeckly v. Hanson

947 N.W.2d 630, 2020 S.D. 45
CourtSouth Dakota Supreme Court
DecidedJuly 29, 2020
Docket29100
StatusPublished
Cited by1 cases

This text of 947 N.W.2d 630 (Moeckly v. Hanson) is published on Counsel Stack Legal Research, covering South Dakota Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Moeckly v. Hanson, 947 N.W.2d 630, 2020 S.D. 45 (S.D. 2020).

Opinion

#29100-a-DG 2020 S.D. 45

IN THE SUPREME COURT OF THE STATE OF SOUTH DAKOTA

****

ANNA MOECKLY and ROGER SCOTT ORR, Personal Representatives of THE SHARON L. ORR-HANSON ESTATE, Plaintiffs and Appellees,

v.

BENNET G. HANSON a/k/a BEN G. HANSON, Defendant and Appellant.

APPEAL FROM THE CIRCUIT COURT OF THE FIRST JUDICIAL CIRCUIT CLAY COUNTY, SOUTH DAKOTA

THE HONORABLE TAMI BERN Judge

ROBERT B. DECK of Deck Law, PLC Sioux City, Iowa Attorneys for plaintiffs and appellees.

MICHAEL A. HENDERSON of Swier Law Firm, Prof. LLC Sioux Falls, South Dakota Attorneys for defendant and appellant.

CONSIDERED ON BRIEFS APRIL 20, 2020 OPINION FILED 07/29/20 #29100

GILBERTSON, Chief Justice

[¶1.] Personal representatives for the estate of Sharon Orr-Hanson brought

a partition action for property owned by Sharon and her husband, Bennet Hanson.

The circuit court held the property was owned as tenants in common and ordered

partition. Hanson appeals, arguing the property was held as joint tenants and

should go to him alone as the surviving joint tenant. We affirm.

Facts and Procedural History

[¶2.] Bennet Hanson (Hanson) and Sharon Orr-Hanson (Sharon) were

married in December 1994. The day of their wedding, Hanson and Sharon entered

into an antenuptial contract, which stated in relevant part that “[i]n the event of

death of either party, any property, real or personal, jointly held by the parties

acquired either prior to marriage or thereafter, shall be that of the survivor.” The

couple lived in Sioux City, Iowa for three years before moving to Burbank, South

Dakota.

[¶3.] They purchased the following described property in Burbank in 1996

“as joint tenants with right of survivorship and not as tenants in common:”

Lot 13 of the Ponderosa Addition and Ponderosa Drive, Parts of Lot 1, Section 2 and Lot 1, Section 3, Township 91 North, Range 51 West of the 5th P.M., and Accretion thereto, Clay County, South Dakota.

In 1998, Hanson and Sharon purchased the lot next door as joint tenants with right

of survivorship as well:

Lot 14 of the Ponderosa Addition and Ponderosa Drive, Parts of Lot 1, Section 2 and Lot 1, Section 3, Township 91 North, Range 51 West of the 5th P.M., and the Accretion thereto, Clay County, South Dakota.

-1- #29100

[¶4.] In December 2006, Craig Thompson, an attorney licensed in South

Dakota, drafted a warranty deed for Hanson and Sharon that conveyed Lot 14 to

themselves. The deed did not contain any language that it would be held as joint

tenants. In April 2007, Thompson drafted another warranty deed, entitled

“Corrective Warranty Deed.” The corrective deed did not correct anything except to

add Lot 13 to the already transferred Lot 14. The corrective deed also contained no

language that the property would be held as joint tenants. In May 2007, Hanson

and Sharon sold Lot 14.

[¶5.] Sharon was diagnosed with pancreatic cancer in October 2016 and

passed away in February 2017. Anna Moeckly, Sharon’s granddaughter, and Roger

Scott Orr, Sharon’s son from her first marriage, acting as personal representatives

(collectively, the Personal Representatives) of her estate, opened a probate in Polk

County, Iowa, where Sharon had been living between her cancer diagnosis and her

death. Sharon’s will stated in relevant part:

I give, devise and bequeath my one-half interest in and to my current residence which is located at 32193 Ponderosa Drive, Burbank South Dakota, to my children, . . . in equal shares, share and share alike, they to have and to hold the same absolutely and forever in fee.

The Personal Representatives opened an ancillary probate in Clay County, South

Dakota to deal with Sharon’s one-half interest in the Burbank property, which they

believed to be held as tenants in common.

[¶6.] In March 2017, Hanson asked Thompson to draft an affidavit for

termination of joint tenancy under SDCL 21-44-27 and gave Thompson the 1996

deed for Lot 13 to base the affidavit on. At that time, Thompson did not remember

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about the 2006 and 2007 deeds he had drafted and proceeded to draft the affidavit

to sever the joint tenancy. However, on May 1, 2017, after the affidavit had been

filed, Thompson sent Hanson a letter indicating that it had come to his attention

that the corrective deed changed the interests in Lot 13 to a tenancy in common, so

the affidavit to sever joint tenancy would have no effect.

[¶7.] The Personal Representatives brought this partition action to have the

property sold and the proceeds split evenly based on the belief that the property was

owned as tenants in common. Both Hanson and the Personal Representatives made

motions for summary judgment. The only dispute of consequence between the

motions was whether the property was held as joint tenants with rights of

survivorship or as tenants in common. The circuit court considered the motions at

separate hearings and denied them both, finding that the issue of how the land was

held was a disputed fact.

[¶8.] Hanson also made a motion to amend the pleadings to add a third-

party complaint against Moeckly, challenging Sharon’s will for undue influence and

lack of testamentary capacity. The circuit court determined that the amendment

would be futile, as Moeckly would not be liable to Hanson for any of Moeckly’s

claims against him in the partition action. In denying the motion, the court noted

that Hanson’s claim would be better brought in the probate matter because “[t]he

contest of a will is not a logical third-party complaint in this action for partition[.]”

The court also denied the motion based on “undue delay, bad faith on the part of the

moving party, and unfair prejudice to the unmoving party.”

-3- #29100

[¶9.] The parties originally set the case for a jury trial, but the Personal

Representatives made a motion to strike Hanson’s jury demand, and the circuit

court granted the motion because partition is an equitable action. The circuit court

later denied Hanson’s motion for reconsideration on that issue as well.

[¶10.] At the partition hearing, Moeckly, Thompson, and Hanson testified.

The court granted Hanson’s motion to exclude expert testimony from Thompson as

irrelevant, so Thompson testified only as to his drafting of the deeds and affidavit

and his interactions with Hanson and Sharon. Thompson recalled a conversation

with Hanson and Sharon in which they asked Thompson to draft the 2006 deed and

stated that they wanted to change the way the property was held to a tenancy in

common. Thompson further testified that he had minimal interactions with Hanson

in the process of drafting the wills, and that he did not remember specifically when

he would have met with Hanson and what the conversations had specifically

entailed. Hanson’s testimony expressed a different recollection of his and Sharon’s

interactions with Thompson. Hanson claimed the conversation regarding changing

the manner in which the property was held to a tenancy in common never

happened, and that he and Sharon met with Thompson at least once before each

deed was signed.

[¶11.] The circuit court held that the corrective deed terminated the joint

tenancy and created a tenancy in common. The court found Thompson’s and

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Bluebook (online)
947 N.W.2d 630, 2020 S.D. 45, Counsel Stack Legal Research, https://law.counselstack.com/opinion/moeckly-v-hanson-sd-2020.