Graham v. Inlow
Arkansas Supreme Court
790 S.W.2d 428 (1990)
Robert Inlow's farm passed to his second wife Freda (defendant), their children, and Patricia Graham (plaintiff), his child from a prior marriage; when Graham petitioned to partition the farm, Freda sought compensation for improvements she'd made, supporting her claim with expert testimony about the value added to individual buildings and how structures generally add value compared to unimproved property, but not testimony about the farm's overall value before versus after the improvements. The trial court ordered the farm sold, awarded Freda $70,000 for improvements, and awarded Graham rents only from the date she filed the partition suit; all parties appealed.
Whether, in a proceeding to partition land among cotenants, a tenant in common may be indemnified for improvements she made on the land in the amount of the difference in value of the property without improvements and the value of the property after improvements.