Lambert v. Quinn

Citations: 798 S.W.2d 448; 32 Ark. App. 184; 1990 Ark. App. LEXIS 624Docket: CA 89-509

Court: Court of Appeals of Arkansas; November 14, 1990; Arkansas; State Appellate Court

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Troy F. Lambert appealed a chancery court decree that reformed a deed he received from James and Deborah Quinn, citing a mutual mistake in the property's description. Lambert argued that there could be no mutual mistake as a matter of law and that the evidence did not support such a finding. The court affirmed the decree, explaining that Garvis Quinn had owned a 1.4-acre home site and an adjoining 1.5-acre tract, of which he retained a .42-acre portion after selling 1.08 acres to Jerry Harris. Following Garvis's death, his will left the home site to his wife, Ruby Quinn, but not the .42-acre parcel. After Ruby made improvements on the .42 acres, the Quinns mistakenly included this land in the deed to Lambert. The chancellor found that both parties were mutually mistaken about the property description, warranting reformation of the deed to exclude the .42-acre tract. The court noted that reformation is an equitable remedy applicable when both parties intended a written agreement to reflect one thing but, due to mutual mistake, it expressed something different. The standard for establishing mutual mistake requires clear and convincing evidence, though not necessarily undisputed proof. Whether mutual mistake occurred is a factual determination.

Chancery cases are reviewed de novo, focusing on whether the trial judge's findings were clearly erroneous rather than whether clear and convincing evidence supports those findings. The appellant contends that mutual mistake cannot be claimed since James Quinn admitted to not reading the deed before signing it, relying on the principle that individuals are bound to the contents of documents they sign. However, this principle, applicable to unilateral mistakes, does not apply in cases of mutual mistake in equity. In reformation actions, the relevant issue is whether the document accurately reflects the mutual agreement of both parties. 

The court found that a mutual mistake occurred, as evidenced by Ruby Quinn's testimony that she believed the 0.42-acre tract was part of her inherited property. The proximity of the property to the home, along with her development of the land (including a swimming pool), supported her claim. James Quinn also testified that he was not aware he owned the 0.42-acre tract when he instructed McDermott to sell his property, indicating he intended to sell only the Harris tract. Testimony from surveyor Shannon Hix confirmed that the 0.42-acre tract's boundaries were unclear to Quinn when he sold the Harris property, as he sought clarification on the survey lines. Opal McDermott confirmed her role in selling all of James Quinn's Cross County property. The court upheld the chancellor's finding of mutual mistake as not clearly erroneous.

The witness denied that she was instructed to sell only a specific tract of land previously owned by Harris. She verified through deed records that James Quinn owned a 1.5-acre property, but she was initially unaware that part of it was used by Ruby Quinn as a yard and mistakenly thought a swimming pool was on Ruby's property. Later, she testified that she considered the pool part of the property being sold at closing. The attorney involved stated he had no contract with James Quinn and received instructions solely from McDermott. Appellant, Mr. Lambert, claimed he intended to purchase the entire 1.5 acres, including various structures, but the chancellor deemed his testimony untrustworthy, noting that his actions indicated he was mistaken about the property's boundaries. The court highlighted Mr. Lambert's failure to mention the pool during negotiations or express any objections during the period from August 1987 to March 1988, despite having opportunities to do so. Testimony from county surveyor Shannon Nix further contradicted Lambert's claims, as Lambert allowed Ruby Quinn's son to place a mobile home on the .42-acre tract containing the pool. The court concluded that accepting Lambert’s claims would imply he was indifferent to the pool's existence, which was implausible. The purchase price reflected the 1.08 acres he acquired, not the pool. The court found Lambert not credible and stated that he received what he paid for. The argument regarding the deed's description was also dismissed, referencing previous rulings on mutual mistakes in contract law. The court affirmed the chancellor's finding of mutual mistake, allowing the deed's reformation, with judges Mayfield and Cooper concurring.