Learning Outcomes
After reading this article, you will be able to explain the right to partition in co-ownership of real property, distinguish between partition in kind and partition by sale, identify who may demand partition, and apply these principles to MBE-style questions. You will also recognize common exam pitfalls and understand the practical consequences of partition orders.
MBE Syllabus
For MBE, you are required to understand the rights and remedies available to co-owners of real property, especially the right to partition. This article focuses your revision on:
- The right of a co-owner to demand partition of real property.
- The difference between partition in kind and partition by sale.
- The procedure and consequences of partition.
- Defenses and limitations to partition.
- The effect of partition on improvements and expenses.
Test Your Knowledge
Attempt these questions before reading this article. If you find some difficult or cannot remember the answers, remember to look more closely at that area during your revision.
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Which of the following statements about partition is correct?
- Only joint tenants may demand partition.
- Partition always results in a physical division of the property.
- Any tenant in common may demand partition at any time.
- Partition is available only if all co-owners agree.
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If a court orders partition by sale, what happens to the proceeds?
- They are divided equally, regardless of ownership shares.
- They are distributed according to each co-owner’s interest.
- The court keeps the proceeds.
- Only the co-owner who requested partition receives proceeds.
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Which of the following is most likely to prevent a court from ordering partition in kind?
- The property is a single-family home.
- The co-owners have unequal shares.
- The property is easily divisible farmland.
- The co-owners disagree about improvements.
Introduction
When two or more people own real property together, disputes can arise about how the property should be used or whether the co-ownership should continue. The law provides a remedy called partition, which allows a co-owner to force the division or sale of the property, ending the co-ownership. Partition is a key remedy for tenants in common and joint tenants, and is frequently tested on the MBE.
Key Term: Partition
The legal process by which a co-owner of real property can force the division or sale of the property, terminating the co-ownership.
Types of Partition
There are two main types of partition:
- Partition in Kind: The property is physically divided among the co-owners, with each receiving a separate portion.
- Partition by Sale: The property is sold, and the proceeds are divided among the co-owners according to their interests.
Key Term: Partition in Kind
A court-ordered physical division of co-owned real property, with each co-owner receiving a separate parcel.Key Term: Partition by Sale
A court-ordered sale of co-owned real property, with the proceeds divided among the co-owners.
Who May Demand Partition?
Any tenant in common or joint tenant has the right to demand partition at any time, regardless of the size of their interest or the reason for the request. Partition is a unilateral right and does not require the consent of the other co-owners.
Key Term: Tenant in Common
A co-owner of real property with an undivided interest that is freely transferable and inheritable, without a right of survivorship.Key Term: Joint Tenant
A co-owner of real property with a right of survivorship; upon death, their interest passes to the surviving joint tenants.
Procedure and Court’s Role
A co-owner seeking partition files a lawsuit. The court will first consider whether partition in kind is feasible and fair. If the property can be divided without prejudice to the owners’ interests, partition in kind is favored. If physical division is impractical or would significantly reduce the property’s value, the court will order partition by sale.
Distribution of Proceeds and Adjustments
When partition by sale occurs, the proceeds are divided according to each co-owner’s share. Courts may adjust the distribution to account for:
- Necessary repairs or improvements made by a co-owner.
- Unequal contributions to expenses (taxes, mortgage payments).
- Rents or profits received by a co-owner in exclusive possession.
Defenses and Limitations
Partition is generally a matter of right, but courts may deny or delay partition if:
- The co-owners have agreed not to partition for a reasonable, limited time.
- Partition would cause great prejudice without a compelling reason.
- The property is subject to a valid restriction on partition (rare).
Effect of Partition on Improvements
If a co-owner has made improvements, the court may award that co-owner the increased value attributable to the improvement, but only if partition by sale occurs. If partition in kind occurs, the improving co-owner may be awarded the improved portion if possible.
Key Term: Ouster
The wrongful exclusion of a co-owner from possession of the property by another co-owner.
Worked Example 1.1
Three siblings inherit a house as tenants in common. One wants to sell, but the others want to keep the house. The sibling seeking sale files for partition. The house is a single-family dwelling and cannot be physically divided. What will the court likely do?
Answer: The court will likely order partition by sale, since physical division (partition in kind) is not feasible for a single-family home. The sale proceeds will be divided among the siblings according to their ownership shares.
Worked Example 1.2
Two friends own a large tract of farmland as joint tenants. One friend has made substantial improvements to part of the land. The other friend files for partition. What is the likely result?
Answer: The court will first consider partition in kind. If feasible, the friend who made improvements may be awarded the improved portion, or the value of the improvements may be credited in the division. If partition in kind is not practical, the court will order partition by sale and adjust the proceeds to account for the improvements.
Exam Warning
Courts strongly prefer partition in kind unless it would be unfair or impractical. On the MBE, look for facts showing that physical division would cause substantial loss in value or is not possible (e.g., a single building).
Revision Tip
Remember: Any tenant in common or joint tenant can force partition at any time, even if the other co-owners object.
Key Point Checklist
This article has covered the following key knowledge points:
- Partition is the right of a co-owner to force division or sale of real property.
- Partition in kind (physical division) is favored unless impractical or unfair.
- Partition by sale is ordered if physical division is not feasible or would harm the property’s value.
- Any tenant in common or joint tenant may demand partition unilaterally.
- Proceeds from partition by sale are divided according to ownership shares, with adjustments for expenses, improvements, and exclusive possession.
- Partition may be limited by agreement, but only for a reasonable time.
Key Terms and Concepts
- Partition
- Partition in Kind
- Partition by Sale
- Tenant in Common
- Joint Tenant
- Ouster