## Facts

- Gabriel Villard died intestate, leaving his widow, Josette, and three daughters as his heirs at law.
- Using proceeds from Villard’s estate, Josette purchased a tract of land in her own name.
- Charles Bebo purchased an adjoining parcel.
- Josette and Bebo later married and sold both parcels to General Lytle.
- With proceeds from the sale to Lytle, Bebo bought a different property from Jacob Ramsdall and received a deed to that property in Bebo’s name alone.
- Josette knew her name was not on the deed at the time of purchase and did not complain then.
- Later, Josette claimed an interest in the property on the ground that the purchase was made, in part, with money traceable to her share of the proceeds from the Lytle sale.
- Bebo agreed with Josette’s claim of an interest, but no conveyance, declaration of trust, or other formal action was taken to place title (or any share of title) in Josette.
- The deed to Bebo was never recorded; it remained in Bebo’s possession until his death and then in Josette’s possession until her death.
- By will, Josette devised her real and personal property to one of Villard’s daughters and the daughter’s husband, John Valicot.
- Valicot and the daughter released whatever claim they had to the disputed property to Ramsdall.
- Ramsdall filed an action to quiet title to the property against W.B. Craighill, the administrator of Bebo’s estate, who claimed possession.
- Two days after Ramsdall filed suit, Craighill sold the land under an order of the court of common pleas to pay Bebo’s debts, which exceeded the value of Bebo’s estate.
- Ramsdall argued that Bebo had defrauded Josette by taking title in his own name and that equity should treat the portion purchased with Josette’s funds as having passed to Josette’s devisees and then to Ramsdall by the release.

## Issues

1. Whether equity would recognize and enforce, against the administrator and creditor sale of Bebo’s estate, a claimed interest in land based on Josette’s alleged contribution to the purchase price where title was taken solely in Bebo’s name and no conveyance or trust was executed.
2. Whether the administrator, acting under an order of the court of common pleas, could sell Bebo’s real estate to pay debts exceeding the estate notwithstanding Ramsdall’s asserted derivative claim through Josette’s devisees.

## Decision

- The Supreme Court of Ohio ruled for Craighill, the administrator of Bebo’s estate, and rejected Ramsdall’s attempt to quiet title based on Josette’s asserted purchase-money claim.
- The court declined to treat Josette’s alleged contribution, without a formal transfer or established trust interest, as creating an enforceable equitable estate in the land that could defeat the administrator’s possession and creditor sale.
- The court upheld the administrator’s court-authorized sale of the land to satisfy Bebo’s debts where the estate was insolvent.

## Legal Principles

- A claim that one person supplied part of the purchase money for land titled in another’s name does not, by itself, establish an enforceable equitable interest against the titled owner’s estate and creditors; equity requires clear grounds and timely action to fix such an interest.
- Where a spouse knows title is taken solely in the other spouse’s name and no deed, trust, or other instrument is executed to secure the claimed share, later assertions of ownership face strong resistance, especially after death and in conflict with creditor administration.
- An administrator acting pursuant to a valid court order may subject a decedent’s real estate to sale to pay debts when the estate is insufficient, and unperfected equitable claims will not ordinarily displace that process.

## Conclusion

Ramsdall v. Craighill holds that Ramsdall could not quiet title by relying on Josette’s later-asserted purchase-money claim and a release from her devisees, where the disputed land had been deeded solely to Bebo and no trust or conveyance was made to secure Josette’s alleged share; the administrator, proceeding under court order, could sell the land to pay Bebo’s debts in an insolvent estate.


Ramsdall v. Craighill, 9 Ohio Reports 197 (1839)