Nicole Williams lived in her mother Estella Williams’ home beginning in 1997. Nicole claimed that she invested some settlement money she had received into making improvements to her mother’s home based on an agreement that her mother would eventually convey her home to Nicole. Estella and Nicole had an argument in 2016 and eventually Estella filed an action to evict Nicole from the home. Nicole filed a petition asking the court to impose a “constructive trust” and compel Estella to transfer the title of her home to Nicole.
At trial, Nicole testified that she and Estella had agreed that if Nicole invested some of her settlement proceeds into Estella’s home, Estella would allow Nicole to stay in the house and would convey title to the house to Nicole. Nicole’s testimony was inconsistent, however, as to whether Estella was going to “will” the house to her or “deed” the house to her. Lucille Williams, one of Nicole’s sisters, testified that she understood that Estella “leav[ing] the house to Nicole” meant that Nicole would receive the house when Estella died. Estella testified that she said she would leave the house to Nicole when she passed away but denied having any sort of arrangement with Nicole for her to do certain things in exchange for Estella leaving the home to Nicole.
Nicole’s testimony that she and Estella both contributed to the bills and upkeep of the home simply amounted to a mutually dependent relationship. Additionally, Estella consistently stated that she never intended to convey her house to Nicole during her lifetime and that devising her home to Nicole was not contingent upon Nicole making repairs to the home.
The chancery court found there was no confidential relationship between Nicole and Estella and that Nicole had not produced sufficient evidence that she relied on Estella’s alleged promise to her detriment. The Court of Appeals affirmed the lower court’s decision, finding that Nicole failed to prove that she and Estella were in a confidential relationship.
Find the court’s opinion here.