Chase Federal Savings and Loan Association v. Schreiber

Theadores Ross conveyed property to Peter Cournoyer through a recorded quitclaim deed stating only “love and affection” as consideration. Cournoyer later sold the property for $50,000 to the Perezes, who financed the purchase through a mortgage from Chase Federal Savings and Loan Association (plaintiff). Ross sued to rescind her deed to Cournoyer, arguing a deed unsupported by valuable consideration is valid only between blood relatives or spouses. The trial court found consideration lacking but held the deed still passed title because the Perezes and Chase Federal had no actual notice of any defect; an intermediate appellate court reversed en banc.