Hammack v. Coffelt Land Title, Inc.

ALOK AHUJA, Judge,

concurring.

I concur fully in the Court’s opinion, and in its reversal of the summary judgment entered in favor of Plaintiff Thomas Ham-mack. As the primary opinion correctly observes, without knowing the terms of the escrow agreement between the Ham-macks and Defendant Coffelt Land Title, it is impossible to say that Hammack is entitled to judgment as a matter of law on either his negligence or breach of contract claims. I write separately because, in my view, reversal is also mandated based on one of Coffelt’s alternative arguments. Since that issue will inevitably recur on remand, in the interest of judicial economy I believe it merits discussion now.

The Hammack Family Farm Trust (the “Trust”) claims an interest in Stanley and Jeannette Hammack’s undivided one-half interest in the 1,040-acre Hammack family farm (the “Property”) only by virtue of a beneficiary deed executed by Stanley and Jeannette Hammack on February 7, 1997. Unless the beneficiary deed effectively transferred the Property to the Trust, Thomas Hammack’s claims against Defendant Coffelt Land Title, Inc. necessarily fail, since they depend on a finding that the proceeds of sale of the Property should have been disbursed to the Trust, rather than to Jeannette Hammack individually.2

Coffelt’s third Point Relied On argues that the summary judgment should be reversed because the evidence creates a genuine issue whether Stanley and Jeannette Hammack effected a transfer of their rights in the Property during Stanley Hammack’s lifetime, which would have the effect of terminating the beneficiary deed on which Thomas Hammack’s claims depend. I agree.

Missouri authorizes beneficiary deeds like the one executed by Stanley and Jeannette Hammack in § 461.025.1,3 which states:

A deed that conveys an interest in real property to a grantee designated by *180the owner, that expressly states that the deed is not to take effect until the death of the owner, transfers the interest provided to the designated grantee beneficiary, effective on death of the owner, if the deed is executed and filed of record with the recorder of deeds in the city or county or counties in which the real property is situated prior to the death of the owner. A beneficiary deed need not be supported by consideration or be delivered to the grantee beneficiary. A beneficiary deed may be used to transfer an interest in real property to a trust estate, regardless of such trust’s revoca-bility.

The relevant Missouri statutes also make clear, however, that “[p]rior to the death of the owner, a beneficiary shall have no rights in the property by reason of the beneficiary designation.” § 461.031.1. Consistent with the fact that a beneficiary deed confers no present interest on the named beneficiary, the nonprobate transfers law specifies that “[a] beneficiary designation may be revoked or changed in whole or in part during the lifetime of the owner.” § 461.033.1. In particular, “[a] transfer during the owner’s lifetime of the owner’s interest in property, with or without consideration, terminates the beneficiary designation with respect to the property transferred.” § 461.033.5. See generally Estate of Dugger v. Dugger, 110 S.W.3d 423, 428-29 (Mo.App. S.D.2003).

Thus, the grantor’s simple act of transferring his interest in property subject to a beneficiary deed, during his lifetime, supersedes and terminates a beneficiary designation with respect to that same property. The question would become, then, whether Stanley and Jeannette Hammack transferred their interest in the Property during Stanley Hammack’s lifetime.

As the majority opinion notes, on December 3, 1998, Stanley, Jeannette, Thomas, and his wife Janet, executed a contract to sell the entire 1,040-acre farm to David Perkins and David Davenport; significantly, the four Hammacks also executed a General Warranty Deed, unconditional on its face, transferring the farm to Perkins and Davenport, and delivered that deed in escrow to Coffelt.

Missouri cases hold that, where a deed is transferred to an escrow agent for delivery to a transferee upon the transferee’s fulfillment of specified conditions (frequently payment of a purchase price), when those conditions are satisfied the transfer is deemed to “relate back” to the date on which the transferor delivered the deed to the escrow agent. Significantly, this rule applies even where the transferor dies between the delivery of the deed into escrow and the ultimate consummation of the transaction. Thus, in Donnelly v. Robinson, 406 S.W.2d 595 (Mo.1966), two life-estate holders executed a deed transferring their interest in certain property to the State Highway Commission on October 5, 1960. On the same day, the deed was delivered to the Wayne County Bank “to be held in escrow by the bank until the check for the purchase price was received from the State Highway Commission.” Id. at 597. The bank/escrow agent received the Highway Commission’s check on November 29, 1960; unfortunately, the life-estate holders were both killed in an automobile accident on October 25,1960, over a month earlier. Despite the fact that the life-estate holders had died, and their life estates had accordingly terminated, before fulfillment of the condition on the sale of their interests, the Supreme Court held that the consummated transaction “related back” to October 5,1960:

The respondents ... rely, as the trial court did, upon the effect of the delivery of the fully executed deed dated October 5, 196[0], to the Wayne County Bank. *181The bank was to deliver this deed to the Missouri Highway Department upon payment of the purchase price. The purchase money was paid; the deed delivered and the respondents contend that the trial court properly held that the date of the concluded transaction related back to the date of the deed and its delivery to the bank....
The court invoked the rule that upon final delivery by a depository of a deed deposited in escrow the instrument will be treated as relating back to, and taking effect at the time of the original deposit in escrow. This shall apply even though one of the parties to the deed dies before the second delivery. This relation back doctrine has wide and general acceptance. Its roots are ancient[,] [dating] as far back as the Sixteenth Century....

id. at 597-98; see also Pipes v. Sevier, 694 S.W.2d 918, 926 (Mo.App. W.D.1985) (where “[a] deed unconditional in terms [is] placed beyond the control of the grant- or upon its delivery to the third party escrow holder,” “ ‘[acceptance after the death of the grantor dates back to the time of the delivery of the deed to the ... [escrow holder] and renders it a transfer as of that date’ ” (citation omitted)); Turner v. Mallernee, 640 S.W.2d 517, 523 (Mo.App. S.D.1982) (“ ‘Properly considered, conditional delivery, or delivery in escrow, is the same as any other delivery, except that it is subject to the satisfaction of a condition. After the condition has been satisfied, there is an operative conveyance which is to be regarded as having been delivered at the time of its conditional delivery ....’” (citation omitted)).4

Here, if Stanley and Jeannette Ham-mack delivered the General Warranty Deed to Coffelt for its delivery to Perkins and Davenport upon their fulfillment of particular conditions, and those conditions were ultimately satisfied and the transaction consummated, under the “relation back” doctrine the transfer would be deemed to have occurred on the date of Stanley and Jeannette Hammack’s original delivery of the deed to Coffelt. The Ham-macks’ original delivery to Coffelt apparently occurred on December 3, 1998, prior to Stanley Hammack’s death. If Stanley and Jeannette Hammack in fact transferred their interest in the Property to Perkins and Davenport effective December 3, 1998, however, this would have the effect of terminating the February 1997 beneficiary deed by virtue of the operation of § 461.033.5, and Thomas Hammack’s claims in the present lawsuit would necessarily fail.

These issues cannot be resolved without knowing the terms and conditions of the escrow agreement entered into between the Hammacks and Coffelt, under which the December 1998 deed was delivered into escrow. Moreover, the situation is complicated by the fact that in February 1999, after Stanley Hammack’s death, Jeannette Hammack executed a Trustee’s Deed conveying the Property to Perkins and Davenport. According to Thomas *182Hammack, Jeannette Hammack’s execution of this Trustee’s Deed was procured by Coffelt, although the factual support for that assertion is not readily apparent. Nevertheless, while the relation-back issue may not be capable of final resolution in this appeal, I believe it does supply an additional ground for reversal of the summary judgment entered by the circuit court.

. It is noteworthy that Jeannette Hammack, who purportedly was paid the sales proceeds in error, is one of the co-Trustees of the Trust, is entitled to income from the Trust during her lifetime, and thus would presumably benefit if Coffelt is required to disburse the sales proceeds a second time (now to the Trust of which she is a beneficiary, rather than to her personally). Although on Plaintiff Thomas Hammack’s theory Jeannette Hammack was the wrongful recipient of over $175,000.00 belonging to the Trust, she has not to this point been named as a defendant or third-party defendant in this action.

.All statutory references are to RSMo 2000.

. Hammack cites Carolan v. Nelson, 226 S.W.3d 923, 923 (Mo.App. W.D.2007), for the proposition that "[i]n Missouri, ... a deed delivered 'in escrow’ is viewed as a conditional delivery that does not effectively pass title to the grantor until the condition is satisfied.” But Carolan does not involve an escrowed deed, and on my reading provides no support for the proposition for which Hammack cites it. Further, even if Hammack is correct that title does not pass in the case of an escrowed deed until any conditions are satisfied, the "relation back" doctrine holds that — once those conditions are satisfied — the transfer is deemed to have occurred as of the date of original delivery into escrow. Thus, even if it were properly supported, Hammack's contention would not avoid application of the "relation back" doctrine.