## Facts

- Nancy Ferguson was a patient of John F. Jeanes, a Christian Science practitioner, and also became his romantic partner.
- Ferguson sought to buy an apartment building (Kirkview Apartments) for herself and asked Jeanes to help locate and negotiate the purchase.
- During negotiations, Jeanes demanded an equal ownership interest; Ferguson initially refused because she wanted sole ownership and security.
- Jeanes used religious and emotional pressure, telling Ferguson she was ungrateful, that refusal violated Christian Science tenets, and that she was incapable of owning and operating the property alone.
- Ferguson ultimately agreed to equal partnership and signed an earnest-money agreement naming Jeanes as a purchaser, but title was taken solely in Ferguson’s name; Jeanes did not sign the mortgage, promissory note, or deed of trust.
- Ferguson advanced nearly $13,000 toward purchase and costs; Jeanes contributed $2,987.50 and largely failed to make further promised payments.
- Ferguson signed a written acknowledgment of Jeanes’s partnership interest, relying on their confidential spiritual relationship and his assurances that he would pay later.
- After the relationship ended, Jeanes sought a quitclaim deed; Ferguson obtained an accounting and offered to reimburse his actual contributions, which he did not accept.

## Issues

1. Whether a confidential spiritual/romantic relationship, coupled with pressure and disparagement, supported a finding that Jeanes obtained the claimed partnership interest through undue influence.
2. Whether rescission of the partnership agreement and quieting title in Ferguson, with restitution to Jeanes for his actual contribution, was an appropriate equitable remedy.

## Decision

- The Court of Appeals affirmed the trial court’s judgment.
- The court upheld findings that Jeanes exercised undue influence arising from a confidential relationship to secure a partnership interest.
- The court held rescission was a proper remedy for a partnership created through undue influence.
- The court approved quieting title in Ferguson while awarding Jeanes restitution of his capital contribution plus interest.

## Legal Principles

- A confidential relationship (including a spiritual practitioner–patient relationship) can impose heightened duties on the dominant party in transactions conferring a substantial benefit.
- When the dominant party in a confidential relationship obtains a significant benefit from the other party, the transaction may be set aside for undue influence unless shown to be fair and free from improper pressure.
- Equity may rescind agreements procured by undue influence, restore the parties as nearly as possible to their prior positions, and grant restitution for actual contributions rather than enforce the influenced bargain.
- Unchallenged trial-court factual findings are binding on appeal and support affirmance if they sustain the legal conclusions and remedy.

## Conclusion

The court affirmed rescission and quiet title because Jeanes, acting from a position of spiritual and personal trust, used undue influence to obtain an equal partnership interest in property largely financed by Ferguson, and equity properly unwound the arrangement while reimbursing his actual investment.


Ferguson v. Jeanes, 619 P.2d 369 (Wash. Ct. App. 1980)