Salter v. Hamiter

Mary Ellen Knowles physically delivered three deeds to Frank Salter (defendant) in front of her attorney, expressing clear intent to transfer title, but asked Salter to hold off recording them until after her death; Salter kept the deeds unrecorded but added a will provision transferring the property back to Knowles if he died first, while Knowles continued using, taxing, and even purporting to sell parts of the properties until her death in 2000, after which Salter recorded the deeds. The executors of Knowles's estate (plaintiffs) sued to void the deeds for insufficient delivery, and the trial court ruled for the executors; Salter appealed.