Wednesday, December 25, 2013

Hoffman v. Chapman case brief

Hoffman v. Chapman case brief summary
34 A.2d 438 (Md. 1943)

Appellant purchasers sought review of a decision of the Circuit Court for Montgomery County (Maryland), which entered a decree reforming their deed. Appellee sellers claimed that the deed mistakenly misidentified the property conveyed.

The sellers agreed to sell part of lot four to the purchasers. That part of the lot had a single dwelling on it, and the purchasers clearly understood that they were receiving only that part of the lot. The deed between the parties, however, conveyed the entire lot. The sellers filed an action in equity to reform the deed. The trial court granted the sellers relief, and the purchasers appealed.


  • The court affirmed. 
  • The court recognized that a lawsuit in equity for reformation was a proper remedy where an instrument did not reflect the parties' true intention and when the evidence was so clear, strong, and convincing as to leave no reasonable doubt that a mutual mistake had been made in the instrument. 
  • The court found that this was such a case. 
  • The court held that there could not have been any doubt as to which dwelling on lot four the purchasers had agreed to buy because they had lived in it for two months before the final payment was made. 
  • The court rejected the purchasers' claim that the mistake was unilateral on the part of the sellers. 
  • The court stated the mere inadvertence or negligence, especially that of the attorney who prepared the deed, did not bar the sellers from relief.

The court affirmed a decree reforming a deed by which the sellers conveyed land to the purchasers.

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