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Fertitta v. Bay Shore Development Corp.

Citations: 291 A.2d 662; 266 Md. 59; 1972 Md. LEXIS 718Docket: [No. 374, September Term, 1971.]

Court: Court of Appeals of Maryland; June 13, 1972; Maryland; State Supreme Court

Narrative Opinion Summary

The case involves a dispute over land ownership arising from a surveyor's error before World War II, which led to the construction of the Ocean Highway in an incorrect location. The appellant, Rosemary Fertitta, inherited land from her father, who had conveyed it to the State Roads Commission in 1940 and again in 1952 with a corrected description. The Commission failed to return the mistakenly conveyed land. Earlier, a court found that Fertitta had equitable title but not legal title, preventing her ejectment action against Bay Shore Development Corporation. The case was remanded to equity court, where the chancellor ruled against Fertitta, except for a small sliver of land. Upon appeal, the court reversed the prior ruling, favoring Fertitta's claim to the disputed land bed of Philadelphia Avenue adjacent to her lots. Bay Shore, initially found to be a bona fide purchaser, was determined not to have conducted sufficient inquiry into the property's title issues. Consequently, the court ruled that Bay Shore's and Skyline's titles were subject to Fertitta's equitable claim, requiring a conveyance to her. The decree was reversed, and costs were assigned to the appellees, with the case remanded for further proceedings consistent with the opinion.

Legal Issues Addressed

Bona Fide Purchaser for Value

Application: Bay Shore was found not to be a bona fide purchaser for value because it failed to conduct an adequate investigation into the known circumstances that suggested a need for further inquiry.

Reasoning: Consequently, Bay Shore was found not to be a bona fide purchaser for value, meaning the quitclaim deed from the Commission did not grant it clear title but rather a title subject to outstanding equities.

Conveyance of Equitable Title

Application: The court concluded that Bay Shore's and Skyline's titles were subject to Fertitta's equitable claim, necessitating a conveyance to her.

Reasoning: Therefore, Bay Shore's title and Skyline's are both subject to Fertitta's equitable claim, necessitating a conveyance to her.

Equitable Title vs. Legal Title

Application: The court ruled that although Fertitta possessed an equitable title, she lacked legal title, which initially prevented her from succeeding in an ejectment action.

Reasoning: In earlier proceedings, the court determined that Fertitta possessed an equitable title but lacked legal title, preventing her from succeeding in an ejectment action against Bay Shore.

Notice to Purchasers

Application: The court emphasized that a purchaser is presumed to have made inquiries if aware of circumstances that suggest the need for investigation, and neglecting such inquiry indicates bad faith.

Reasoning: The legal principles applicable to purchasers regarding notice of prior equities or unrecorded interests were articulated in Williams v. Skyline Dev. Corp., emphasizing that a purchaser is presumed to have made inquiries if aware of circumstances that suggest the need for investigation.