| Court: | Colorado Supreme Court |
| Facts: | Taylor owned a ranch. He conveyed it to joint tenancy with Lucy Canterbury. Then he tried to quit-claim it back to tenancy in common. Then he died. |
| Posture: | Canturbury sues to set aside the conveyance so she can still be a joint tenant. |
| Issue: | Can one joint tenant unilaterally sever the joint tenancy? |
| Holding: | Yes. |
| Rule: | Just issuing a deed conveying the property is sufficient to sever the tenancy. |
| Reasoning: | Colorado used to be all uptight about having to sever some of the four unities (i.e., has to go through a straw-person transfer, because the tenant's own interest is also severed) in order to sever co-tenancy. The court says that's archaic, and just blind servitude to form. |
| Dicta: | Dissent: it is dangerous to set aside well-known principles of property law. |