## Facts

- After her husband’s death, Florence L. Dietz relied on her son, Donald E. Dietz, who managed her financial affairs and acted as her advisor.
- Florence bought a duplex, paying $5,200 from her own funds and financing the remainder with a $4,800 mortgage.
- Title to the duplex was placed in Florence and Donald as joint tenants.
- The trial court found that the joint-tenancy conveyance was made in consideration of Donald’s oral promise to support Florence for life.
- Donald denied any support agreement and claimed the purchase money was his.
- After Donald married Virginia, cohabitation with Florence deteriorated; conflict culminated in a March 1950 incident in which Donald refused Florence food, told her to leave, and used physical force that caused bruising.
- Florence moved out; Donald and Virginia did not support her afterward.
- Florence sued for an accounting and to recover the real estate interest transferred to Donald; the trial court ordered Donald to convey his interest to Florence and denied Donald’s motion for a new trial.

## Issues

1. Whether the evidence sufficiently supported the finding that Donald received a joint-tenancy interest in exchange for an oral agreement to support Florence for life.
2. Whether equity could compel conveyance of Donald’s joint-tenancy interest (constructive trust-type relief) despite the oral nature of the support agreement and the deed’s terms.
3. Whether the trial court erred in denying Donald’s motion for a new trial based on claimed insufficiency of evidence and improper legal conclusions.

## Decision

- The Minnesota Supreme Court affirmed the order denying a new trial, leaving the judgment for Florence in place.
- The court held the evidence supported the finding of an oral lifetime-support agreement that induced Florence to place title in joint tenancy.
- The court held Donald’s substantial nonperformance and repudiation justified equitable relief requiring him to convey his interest to Florence.
- The court deferred to the trial court’s credibility determinations and declined to reweigh conflicting testimony where findings had record support.

## Legal Principles

- Appellate courts generally uphold trial-court findings based on witness credibility and conflicting evidence if the record reasonably supports those findings.
- When a person obtains title or an interest in property through an oral promise of lifetime support, and the promise is materially breached, equity may impose relief that strips the promisor of the obtained interest.
- A confidential or trust-based relationship between transferor and transferee supports equitable intervention where the transfer was induced by reliance on the transferee’s promise and the transferee later fails substantially to perform.

## Conclusion

The court affirmed equitable divestiture of a son’s joint-tenancy interest where the interest was obtained through an oral lifetime-support promise to his mother and the evidence supported a substantial breach and repudiation of that obligation.


Dietz v. Dietz, 70 N.W.2d 281 (Minn. 1955)