## Facts

- Frank Ashton owned real property and two water shares in Hurricane, Utah.
- Frank wanted the east half of the property and one water share to go to his brother, Woodruff Ashton, and the west half and one water share to go to his brother, Wilford Ashton.
- Because Woodruff had marital problems, Frank conveyed all property and both water shares to Wilford Ashton and Wilford’s wife, Virginia M. Ashton, as joint tenants with right of survivorship.
- The conveyance was conditioned on Wilford’s promise that, once Woodruff’s marital problems were resolved, Wilford and Virginia would convey the east half and one water share to Woodruff.
- After Frank’s death, Wilford and Virginia refused to convey any interest to Woodruff, including after Woodruff’s divorce.
- Woodruff sued to quiet title and sought imposition of a constructive trust for the promised interest.
- After a three-day trial with an advisory jury, the trial court imposed a constructive trust awarding Woodruff the east half of the property and one water share.
- Wilford and Virginia appealed, challenging the constructive trust (including as to Virginia), the sufficiency of evidence of a confidential relationship and promise, and certain evidentiary and trial-management rulings.

## Issues

1. Whether the evidence supported findings of a confidential relationship and a promise to reconvey sufficient to justify a constructive trust in favor of Woodruff.
2. Whether a constructive trust could extend to Virginia’s joint-tenancy interest where she argued she did not share the relevant confidential relationship with Frank.
3. Whether the trial court committed reversible error in excluding an expert witness and in handling trial and jury-related matters connected to Wilford’s health and participation.

## Decision

- The Utah Supreme Court affirmed the judgment imposing a constructive trust over the east half of the property and one water share for Woodruff.
- The court held the record supported the trial court’s findings that Frank conveyed title in reliance on Wilford’s promise within a confidential relationship.
- The court held Virginia’s joint-tenancy interest was subject to the same constructive trust because her title derived from the same conditioned conveyance and was not based on an independent bargain or consideration.
- The court found no abuse of discretion or prejudicial error in the challenged evidentiary ruling or in trial management and jury instructions.

## Legal Principles

- A constructive trust may be imposed in equity to prevent unjust enrichment when property is obtained or retained through inequitable conduct, including breach of a promise made and relied upon in the context of a confidential relationship.
- Appellate review defers to trial-court factfinding; findings will not be disturbed unless clearly erroneous when supported by substantial evidence, especially where credibility assessments are central.
- A spouse receiving a joint-tenancy interest through the same transaction that created the equitable obligation may be bound by a constructive trust and cannot claim a better position than the obligated grantee absent an independent equitable basis (e.g., separate consideration).

## Conclusion

The court upheld a constructive trust enforcing a family arrangement under which title was transferred to a brother and his wife on the condition that they later convey a defined portion to another sibling; equity required reconveyance, and the wife’s joint-tenancy interest remained subject to the trust because it arose from the same conditioned transfer.


Ashton v. Ashton, 733 P.2d 147 (Utah 1987)