## Facts

- Joseph B. Sieger (husband), unable to read or write, entrusted his wife, Amelia Sieger, to purchase the home where they lived and believed title would be taken in his name.
- Joseph furnished $2,000 toward the $3,400 purchase price from the sale of his other property; the remainder was paid largely from Amelia’s funds.
- Contrary to Joseph’s understanding and without his knowledge or consent, Amelia procured and recorded a deed naming herself as sole grantee.
- Joseph discovered the titling about 16 months later, demanded a conveyance reflecting his interest, and Amelia refused.
- The trial court found Joseph owned an undivided two-fifths interest and that Amelia held legal title to that interest in trust for him; Amelia appealed.

## Issues

1. Whether equity should impose a constructive trust in favor of the husband on real property titled solely in the wife’s name when she took title contrary to his instructions and confidence.
2. Whether the facts support a constructive trust rather than a resulting trust.
3. Whether the presumption that the husband intended a gift or advancement when title is taken in the wife’s name was rebutted.
4. Whether the wife’s conduct constituted a “violation of some trust” permitting enforcement of the trust notwithstanding the statute of frauds (Minn. G.S. 1923 § 8088).

## Decision

- The Supreme Court of Minnesota affirmed.
- Equity imposed a constructive trust on an undivided two-fifths interest in favor of Joseph.
- The court treated the case as involving a constructive trust grounded in wrongful conduct and abuse of confidence, not merely a purchase-money resulting trust.
- The presumption of gift/advancement to the wife was rebutted by evidence of Joseph’s reliance, his expectation that title be in his name, and Amelia’s unilateral titling.
- Amelia’s actions constituted a “violation of some trust” under § 8088, allowing equitable relief despite the lack of a written trust instrument.

## Legal Principles

- A constructive trust may be imposed where one party, in a confidential relationship, wrongfully takes or holds title contrary to the other party’s instructions or justified reliance.
- Resulting trusts generally rest on inferred intent from payment of consideration; constructive trusts rest on preventing unjust enrichment from fraud, breach of confidence, or similar wrongdoing.
- When a definite portion of the purchase money is supplied by one person and title is taken in another’s name, a trust may exist pro tanto to the extent of the definite contribution, and the equitable interest may be expressed as an aliquot share.
- When a spouse pays and title is taken in the other spouse’s name, the presumption of gift/advancement is rebuttable and may be overcome by evidence showing no donative intent and wrongful procurement of title.
- A “violation of some trust” within the governing statute of frauds exception permits enforcement of an equitable trust in land without a writing.

## Conclusion

The court upheld a constructive trust for the husband’s two-fifths interest because the wife, entrusted to complete the purchase, wrongfully took title in her own name, rebutting any presumption of a gift and constituting a statutory “violation of some trust” warranting equitable relief.


Sieger v. Sieger, 162 Minn. 322, 202 N.W. 742 (Minn. 1925)