Grant v. Kahn
Maryland Court of Appeals
18 A.3d 91 (2011)
Grant (defendant/buyer) contracted to buy Ganz's house subject to a financing contingency; before the sale closed, the Kahns (plaintiffs) obtained a money judgment against Ganz, and shortly after, Grant and Ganz closed the sale. The Kahns then sought to execute their judgment against the house as a lien, and Grant argued the doctrine of equitable conversion meant he already held equitable title from the contract's execution date, predating the Kahns' judgment; the circuit court sided with the Kahns, finding the financing contingency defeated equitable conversion.
Whether, under the doctrine of equitable conversion, a judgment entered against a seller of real property after the sales contract's execution becomes a lien on the property.