Peterka v. Janda

2025 ND 38
CourtNorth Dakota Supreme Court
DecidedFebruary 13, 2025
DocketNo. 20240122
StatusPublished
Cited by1 cases

This text of 2025 ND 38 (Peterka v. Janda) is published on Counsel Stack Legal Research, covering North Dakota Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Peterka v. Janda, 2025 ND 38 (N.D. 2025).

Opinion

IN THE SUPREME COURT STATE OF NORTH DAKOTA

2025 ND 38

Jared Peterka, Plaintiff and Appellant v. John E. Janda and Irene C. Janda, individually and as Co-Trustees of the John E. Janda and Irene C. Janda Living Trust, established October 30, 2018; Jacqueline Korczak, individually, and as co-guardian and co-conservator of John and Irene Janda, as Successor Trustee of the John E. Janda and Irene C. Janda, established October 30, 2018; Loretta Grad, individually, and as co-guardian and co-conservator of John and Irene Janda, Defendants and Appellees and Catherine Enstad, Defendant

No. 20240122

Appeal from the District Court of Traill County, East Central Judicial District, the Honorable Steven E. McCullough, Judge.

AFFIRMED.

Opinion of the Court by Tufte, Justice.

Andrew D. Cook, West Fargo, N.D., for plaintiff and appellant.

Matthew D. Kirschenmann (argued) and Michael T. Andrews (on brief), Fargo, N.D., for defendants and appellees. Peterka v. Janda No. 20240122 Tufte, Justice.

[¶1] Jared Peterka appeals from a district court judgment denying his claim for declaratory judgment and dismissing his complaint. On appeal, he argues the district court clearly erred by determining his option contract was voidable under N.D.C.C. § 14-01-02. We affirm the judgment.

I

[¶2] John and Irene Janda (collectively “the Jandas”) owned farmland in Walsh County, North Dakota, namely Section 19-156-53 (“the disputed property”). Jacqueline Korczak, Loretta Grad, and Catherine Enstad (collectively “the Defendants”) are the adult daughters of the Jandas. Jared Peterka was a neighbor and tenant of the Jandas.

[¶3] Jared Peterka’s father leased the disputed property for many years. In 2012, Jared Peterka assumed the lease and began farming the land. The lease was renewed every three years, and in 2019 a right of first refusal for Jared Peterka to purchase the land was added to the lease. In October 2018, the Jandas established a living trust and conveyed the disputed property into the trust. The Defendants are the residuary beneficiaries of the trust.

[¶4] On May 20, 2021, Irene Janda was admitted into a nursing home to recover from a broken hip. On May 25, 2021, John Janda was admitted into the same nursing home because “he was unable to care for himself safely without assistance.” On June 14, 2021, the Jandas and Peterka executed an option to purchase the disputed property. On July 15, 2021, guardianship and conservatorship proceedings were commenced on behalf of the Jandas. On October 14, 2021, the Jandas were found to be incapacitated, and permanent guardianships were ordered under N.D.C.C. ch. 30.1-28. Two of the Defendants were appointed guardians. The guardians rescinded the option to purchase the disputed property.

1 [¶5] Jared Peterka filed a complaint for declaratory judgment seeking declaration that his option to purchase the disputed property is valid and enforceable. The Defendants answered and filed a counterclaim, arguing the option to purchase was the result of undue influence exerted by Peterka upon the Jandas and the Jandas lacked capacity to execute the option in June of 2021. A four-day bench trial was held in July 2023.

[¶6] Following trial, the district court entered a memorandum opinion and order finding the option to purchase was facially valid, not the product of undue influence, and not void for lack of capacity. The court further found the option to purchase was voidable under N.D.C.C. § 14-01-02, and the option was voided when the Defendants rescinded the option to purchase. The court denied Peterka’s request for declaratory judgment and dismissed his complaint. Judgment was entered. Peterka appeals.

II

[¶7] Peterka argues the district court’s findings on capacity are clearly erroneous because they are induced by an erroneous view of the law. He argues the court’s finding that the Jandas had capacity to enter into the option to purchase precludes a finding that the Jandas were of unsound mind, but not entirely without understanding under N.D.C.C. § 14-01-02. He argues the capacity to enter into a contract is the same capacity contemplated in N.D.C.C. § 14-01-02.

[¶8] “A district court’s finding on capacity, or lack of capacity, is a question of fact.” Vig v. Swenson, 2017 ND 285, ¶ 14, 904 N.W.2d 489; see also Slorby v. Johnson, 530 N.W.2d 307, 310 (N.D. 1995) (“findings concerning capacity and competency are questions of fact which will not be overturned on appeal unless they are clearly erroneous under N.D.R.Civ.P. 52(a)”). “We will not set aside a district court’s finding of fact unless it is clearly erroneous.” Vig, ¶ 14 (citing N.D.R.Civ.P. 52(a)). “A finding of fact is clearly erroneous if it is induced by an erroneous view of the law, if no evidence supports it, or if, on the entire record, we are left with a definite and firm conviction a mistake has been made.” Id.

2 [¶9] “Appellate courts review the record and findings as a whole and if the controlling findings are supported by the evidence, they will be upheld on appeal notwithstanding immaterial misstatements in the lower court’s decision.” Pomarleau v. Pomarleau, 2022 ND 16, ¶ 24, 969 N.W.2d 430 (citations omitted). Furthermore, “[w]e will not set aside a district court’s decision simply because the court applied an incorrect reason, if the result is the same under the correct law and reasoning.” Sholy v. Cass Cnty. Comm'n, 2022 ND 164, ¶ 14, 980 N.W.2d 49 (citations omitted).

III

[¶10] Peterka argues the district court’s finding that the Jandas had capacity to enter into the option to purchase precludes a finding that the Jandas were of unsound mind, but not entirely without understanding under N.D.C.C. § 14-01- 02. We disagree, and conclude a finding that a contract was not void for lack of capacity to enter into a contract does not preclude a finding the contract was voidable under N.D.C.C. § 14-01-02. We agree certain passages in the district court’s order create confusion. However, we conclude the district court’s findings are not based on an erroneous view of the law, and the court’s findings under N.D.C.C. § 14-01-02 are supported by the evidence.

[¶11] The district court found the option to purchase was not void for lack of “contractual capacity” or the capacity to enter into a contract. Peterka does not dispute this finding. The court then analyzed the Jandas’ capacity under N.D.C.C. ch. 14-01 and found the Jandas lacked “guardianship capacity” under N.D.C.C. § 14-01-02, rendering the option to purchase “voidable.” The court explained:

Section 14-01-02 also provides guidance for situations like the present, when a contract is executed by a proposed ward shortly before a guardianship is ordered. In this sense, the phrase “was not entirely without understanding” as used in this statute is the same as “having a general understanding of the nature and effect of the transaction” under the three-prong test for “contract capacity.” Thus, even when a person has the limited “contract capacity” under the three-prong test set forth above . . . , if that person actually lacked “guardianship capacity” (even though not yet judicially

3 determined) the person (by and through his guardian) could rescind a contract after a guardianship is put in place. In other words, the contract is voidable in favor of the person who “was not entirely without understanding,” (or had the three-prong cont[r]act capacity) by the person’s later guardian.

The court also explained “for purposes of interpretation of these statutes, ‘a person entirely without understanding’ equals ‘a person of unsound mind’ equals a person whose ‘incapacity has been judicially determined’ equals a person whose contracts are null and void.”

A

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Bluebook (online)
2025 ND 38, Counsel Stack Legal Research, https://law.counselstack.com/opinion/peterka-v-janda-nd-2025.