Fahey v. Fife

Absent clear error, a district court's valuation of a decedent's estate will not be reversed on appeal. Plaintiffs Anne Fahey, Timothy Fife and Richard D. Fife appealed a district court judgment in their action seeking cancellation of a quit claim deed from their deceased mother Marianne Fife to their deceased father Richard A. Fife relating to North Dakota minerals. Anne Fahey's aunt Carole Hill informed her about the circumstances surrounding Marianne’s conveyance of her mineral interest. Hill witnessed Richard Fife present a quit claim deed for Marianne to sign, and Richard held Marianne's hand to help her sign her name on the deed. Hill believed Marianne was not competent at the time to sign the deed, and was not informed as to what she was signing. Plaintiffs sued Joanne Fife, individually and as personal representative of Richard Fife's estate, claiming their mother lacked capacity to execute the deed because she was under medication to treat her pain. Plaintiffs also claimed their father exercised undue influence over their mother when she signed the deed. The trial court rescinded the deed but concluded that under North Dakota's intestacy laws in effect at Marianne’s death, the minerals passed to Richard A. Fife. The court concluded Richard A. Fife's surviving spouse Joanne Fife owned the minerals. Finding no reversible error, the North Dakota Supreme Court affirmed. View "Fahey v. Fife" on Justia Law