Dunham v. Dunham

LANSING, Judge,

dissenting.

I dissent from the majority’s conclusion that only a gift of money, not a transfer of an interest in real property occurred, and that Carl Dunham’s claim must therefore fail because his complaint challenged only a conveyance of real property from Roger Dunham to Belinda Dunham.

The district court and the majority of this Court make what is, in my view, an artificial distinction between the alleged monetary gift *59from Roger to Belinda and the purchase of real property in Belinda’s name alone. Their analysis depends upon an assumption that there was first a completed gift of money and then a later, independent real estate purchase by Belinda. The trial evidence showed, however, that there was an integral relationship between the transfer of money and the use of that money as the down payment on the land to which Belinda took title.

A valid gift is not made until the property has been delivered to the donee and the donor has relinquished all dominion over the gifted asset. Matter of Estate of Lewis, 97 Idaho 299, 302, 543 P.2d 852, 855 (1975); Boston Insurance Co. v. Beckett, 91 Idaho 220, 222, 419 P.2d 475, 477 (1966). Therefore, there was no accomplished gift of money from Roger to Belinda unless and until Roger delivered the funds to Belinda. The evidence as to when and how Roger transferred the inherited funds to Belinda or for her benefit is not well-developed. However, the financial statement dated September 14, 1989, that Belinda submitted in support of her application for a mortgage loan to purchase the property, indicates that as of that date the inherited money was still held in a trust account of the decedent’s estate in a bank in Connecticut. At trial, Roger testified as follows:

Q. To the best of your knowledge who requested the quitclaim deed be prepared?
A I believe it was the bank or the title, I think it was the bank, the lending institution is the one who wanted it.
Q. Do you have any opinion as to why they would want that?
A I think it was because the check was from the Connecticut bank from the trust of my aunt and it was made out to me. And I think they were concerned that they were lending money to my wife, and if the check was signed by me that I have no interest in it since they were lending the money to my wife.

This testimony suggests that Roger did not gift the money to Belinda before the real estate purchase but that the money was delivered at the closing of the real estate transaction in the form of a check from his aunt’s estate to Roger which was then conveyed to the closing agent. This is the only testimony that bears upon the transfer of the funds from Roger. There is no testimony that the money was delivered to Belinda at any time prior to or separate from the consummation of the real estate transaction in mid-September 1989 and, thus, no showing of an independent gift of the money.

In sum, the uncontradieted evidence showed that money belonging to Roger, promptly upon leaving Roger’s control, was used as the down payment in the real property purchase, that title to the property thus acquired was taken in Belinda’s name, and that Roger simultaneously transferred to Belinda by quitclaim deed any interest that he held in the real property.

Regardless of the precise date when the funds were transferred or to whom, the substance of the transaction is that Roger’s money was used to purchase real property and that Roger relinquished to Belinda any interest in the real property, to the detriment of Roger’s creditors. This was in substance a conveyance of a real property interest made without a reasonably equivalent value in exchange, which falls within the purview of I.C. §§ 55-913(l)(b) and 55-914.

The defendants’ characterization of this interchange as a gift of money rather than a gift of real property is just that — a convenient post hoc characterization. The Court should look beyond either party’s interpretation to the substance of the transaction. See, e.g., Pennington v. Bigham, 512 So.2d 1344, 1347 (Ala.1987) (“[T]he form of the transaction by which property, liable to the satisfaction of the demands of creditors, is fraudulently sought to be placed beyond their reach is not material. This Court looks beyond mere form to the substance of the transaction.”); Tacoma Association of Credit Men v. Lester, 72 Wash.2d 453, 433 P.2d 901, 903 (1967) (in a fraudulent conveyance action, “courts will invariably look to the substance of a transaction rather than its form.”).

Very similar circumstances were presented in D.H.R. Construction Co., Inc. v. Donnelly, *60180 Conn. 430, 429 A.2d 908 (1980), where a debtor had made a gift to his wife of $3,000 which he had recently borrowed. It was asserted by a creditor that the debtor made this gift for the purpose of buying residential property, that title to the property was put in the wife’s name alone, and that the debtor thereafter made monthly payments on the mortgage. The creditor brought a fraudulent conveyance action alleging that the debt- or had caused the real property to be conveyed to his wife without consideration. The trial court granted summary judgment to the defendant debtor, reasoning, as did the district court here, that the debtor “did not own the property and did not transfer it to [his wife].” The Connecticut Supreme Court reversed the summary judgment, stating:

We conclude that there is no inherent difference between the act of a debtor conveying his property to another without consideration and that of a debtor causing the title to the property purchased to be placed in the name of another, where the object of such transfer is to hinder, delay or defraud creditors.

Id., 429 A.2d at 910. The Connecticut Supreme Court’s approach is reasonable and fair and should be followed here.

It certainly would have been better practice for Carl’s complaint to have alleged both the asserted gift of money and the conveyance of real property as fraudulent transfers, and a more complete record as to exactly how the transaction occurred could have been made at trial. Nonetheless, the substance of what was proved — an acquisition in Belinda’s name of real property purchased with Roger’s assets — was, in its essence, a relinquishment to Belinda of an interest in real property that Roger otherwise would have held as a consequence of his contribution of the down payment. Accordingly, I cannot agree with my colleagues’ conclusion that Carl’s claim is defeated because his complaint alleged a fraudulent transfer of an interest in real property rather than a fraudulent gift of money.