Todd Evan Fogal v. Neil Edward Fogal

CourtCourt of Appeals of Texas
DecidedMay 4, 2023
Docket09-21-00264-CV
StatusPublished

This text of Todd Evan Fogal v. Neil Edward Fogal (Todd Evan Fogal v. Neil Edward Fogal) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Todd Evan Fogal v. Neil Edward Fogal, (Tex. Ct. App. 2023).

Opinion

In The

Court of Appeals

Ninth District of Texas at Beaumont

__________________

NO. 09-21-00264-CV __________________

TODD EVAN FOGAL, Appellant

V.

NEIL EDWARD FOGAL, Appellee

__________________________________________________________________

On Appeal from the 136th District Court Jefferson County, Texas Trial Cause No. D-207,387 __________________________________________________________________

OPINION

Complaining the trial court erred in finding that a lot in the City of

Beaumont (the Property) is jointly owned, 1 Todd Evan Fogal appeals

1The Property is more fully described as Lot Number Forty-three (43) and the East one foot (E. 1’) of Lot Forty-two (42), in Block Number One (1), of REGENCY PARK ADDITION to the City of Beaumont, Jefferson County, Texas, according to the map or plat of record in Volume 10, Page 142, of the Map Records of Jefferson County, Texas; commonly known as 7645 Wickersham Place, Beaumont, Jefferson County, Texas. 1 from an order granting Neil Edward Fogal’s application to compel the

Property’s partition and sale. On appeal, Todd contends that he became

the sole owner of the property upon his mother’s death. Todd traces his

ownership of the Property to a 2014 conveyance from the Fogal Family

Trust, in which the trustee of the Trust conveyed the property to him and

to his mother as joint owners with “rights of survivorship.” But Todd’s

problem is that around four years later in 2018, his mother conveyed her

undivided interest in the Property to her other son, Neil. So, when

Marjorie died in 2021, she no longer owned an undivided interest in the

Property, leaving her sons to resolve the issue over the Property that led

to this dispute. The trial court resolved the dispute in Neil’s favor. On

appeal, Todd claims his survivorship rights in the Property were not

destroyed by his mother’s conveyance of her undivided interest in the

Property to Neil.

Because we conclude the 2014 deed from the Trust did not restrict

Marjorie’s power to convey her undivided interest in the Property to Neil,

Todd and Neil became joint owners of the Property in 2018 when Marjorie

conveyed the property to Neil. Because we conclude the trial court

correctly ordered a partition of the Property, we will affirm.

2 Background

Marjorie Ann Fogal is Todd’s and Neil’s mother. As is relevant here,

in 2014 Marjorie was the trustee of the Fogal Family Trust. As the

trustee of the Trust, she signed a deed conveying the Property from the

Trust jointly to herself and Todd.

In the trial court and on appeal, no one has challenged Marjorie’s

powers under the Trust to convey property from the Trust to herself or

her sons. 2 Todd also has not claimed that Marjorie didn’t have the mental

capacity required to execute the 2018 deed conveying her undivided

interest in the Property to Neil. Rather, the question they contest

concerns the legal effect of the language in the two deeds.

On one hand, Todd contends the 2018 deed his mother signed

conveying the Property to Neil did not cut off his survivorship rights in

the Property, a survivorship right he acquired under his deed from the

Trust. According to Todd, his survivorship right matured when, in March

2Generally, unless authorized by the powers given to the trustee in the instrument creating the trust, a trustee isn’t authorized to buy property from the trust or sell property to a relative of the trustee. Tex. Prop. Code Ann. §§ 113.001, 113.053(a). That said, the instrument that created the Trust is not before us, and as already mentioned, no one challenged Marjorie’s powers under the Trust. 3 2021, Marjorie died and when that occurred the Property reverted to him.

On the other, Neil contends that he and Todd became tenants in common

in the Property when his mother conveyed her undivided interest in the

Property to him. Neil also argues that by conveying an undivided interest

out of a joint tenancy, a joint tenant destroys whatever benefit the

surviving joint tenant might have received under the survivorship clause

of a joint tenancy deed.

Turning to the text of the 2014 deed, nothing in it prevented

Marjorie from conveying her undivided interest in the Property to

someone else. Instead, the granting clause provides that Marjorie (as

trustee of the Trust) grants the Property to Marjorie and Todd “as joint

owners with rights of survivorship . . . and not as tenants-in-common.”

Then in March 2018, Marjorie conveyed “All of Grantor’s undivided

interest in” the Property to Neil. Under the 2018 deed to Neil, Marjorie

reserved a life estate in the Property, but provided that “[u]pon the death

of Grantor, full record title shall vest in Grantee.” The 2018 deed

identifies Marjorie as the Grantor and Neil as the Grantee.

After Marjorie’s death in 2021, Neil sued Todd and sought an order

partitioning the Property. He also asked the trial court to order the

4 Property sold. 3 Todd answered the petition, filed a cross-action, and

asked for a declaratory judgment to “straighten out title” under the two

deeds. Todd alleged that “because he survived Marjorie Ann Fogal[,]” he

owns the property’s entire fee.

After Todd answered, Neil moved for summary judgment. In his

motion, Neil argued that based on the deed his mother signed in 2018,

Todd’s joint tenancy with Marjorie ceased to exist. According to Neil’s

motion, the conveyance in 2018 made him a tenant in common in the

Property with Todd, which before 2018 had been jointly owned by Todd

and their mother. So Neil concluded that as a cotenant with Todd, he

(Neil) had an absolute right to a court order requiring the Property to be

partitioned and sold. Neil added the procedures to be followed in any

court-ordered sale are the procedures in Chapter 23A of the Property

Code, as the Property is Heirs’ property as that term is defined by section

23A.002(5) of the Property Code. 4

3Id. §§ 23A.001-.009 (the Uniform Partition of Heirs’ Property Act). We didn’t mention the date Neil sued because the Plaintiff’s Original Petition isn’t in the Clerk’s Record, and we can’t determine from what is included in the appellate record when the suit was first filed. 4Id. § 23A.002(5) (defining Heir’s property as “real property held in

tenancy in common that satisfies” the requirements listed in section 5 Besides his claims seeking affirmative relief as to the Property

itself, Neil moved for summary judgment on Todd’s crossclaim alleging

that he (Todd) acquired Marjorie’s undivided interest in the property

when she died and on Todd’s request for declaratory relief. Neil relied on

the same arguments—that the 2018 deed cut off Todd’s right of

survivorship claim—that he relied on to seek an order that the Property

be partitioned and sold. As for Todd’s Declaratory Judgments Act claim,

Neil argued the claim should be dismissed because: (1) the dispute was

already before the trial court when Todd filed his cross-action seeking

declaratory relief; and (2) declaratory judgment actions are not the

proper form of actions that resolve questions over who has title to land.

According to Neil, claims to resolve issues of title must be tried as actions

in trespass to try title.

Neil attached the following evidence to his motion for summary

judgment: (1) a copy of Todd’s Answer and Cross-Action; (2) a copy of the

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Todd Evan Fogal v. Neil Edward Fogal, Counsel Stack Legal Research, https://law.counselstack.com/opinion/todd-evan-fogal-v-neil-edward-fogal-texapp-2023.