Brackenbury v. Hodgkin

1917

Court: Supreme Court of Maine

Facts: Sarah Hodgkin owns some land, and needs help. She gets her daughter and son-in-law to move to Maine to take care of her and the land, which she puts in trust for them. They come, but in the first few weeks, trouble brews and she wants them out. So she executes a deed giving her son Walter the premises, but reserving a life estate for herself. But Walter knew of the agreement with the Brackenburys, so he was not a "bona fide purchaser without notice."

Posture: Walter tries to evict the couple. They sue for a reconveyance of the farm to them, and an enjoinment against Walter to quit evicting them. Finding was for the couple, defendants appeal.

Issue: Four issues:
  1. Is there a valid contract?
  2. Do the young couple have an equitable interest in the land?
  3. Did plaintiffs breach?
  4. Can they get relief at law?

Holding:
  1. Yes-- the offer was in writing, and it was a unilateral contract, so the second party need do nothing.
  2. Yes-- the document gives them an interest when they start performing.
  3. No-- Mrs. Hodgkin is the one at fault here... apparently she is disagreeable
  4. No-- generally relief at equity (such as the one granted by the trial court) would be unavailable when a remedy at law is available, but in the case of trusts, in Maine, statute specifically permits equity resolutions.

Rule: See holding

Reasoning: See holding; this was very brief

Dicta: