## Facts

- Donald G. Stauffer and Theresa E. Stauffer married in 1953 and owned their marital home as tenants by the entireties; the land was gifted by Theresa’s parents, and the house was paid for primarily from Donald’s earnings.
- In late March or early April 1970, Donald confessed to an adulterous relationship with Theresa’s sister, which had ended in late March 1970.
- Between March 26 and April 23, 1970, Theresa consulted an attorney multiple times while she and Donald continued to live together and engage in marital relations, and she indicated interest in reconciliation.
- On April 23, 1970, Donald and Theresa jointly deeded the entireties property to Theresa alone for nominal consideration.
- Donald testified he conveyed his interest to preserve the property as the family home and believed it would remain the family residence for both spouses and their children.
- The chancellor found Theresa induced the conveyance through threats and misrepresentations, including claims that litigation by her brother-in-law could cause the family to lose the home unless title was placed solely in her name.
- Shortly after the deed was executed, Theresa ended marital relations and moved out of the marital bedroom.
- Donald filed an equity action seeking to impose a constructive trust and compel reconveyance; the trial court granted relief, and the decree was made final after exceptions were dismissed.

## Issues

1. Whether Theresa’s conduct fraudulently induced Donald to convey his interest in entireties property, warranting imposition of a constructive trust and reconveyance.
2. Whether a confidential marital relationship existed at the time of the conveyance sufficient to support equitable relief and related burdens of proof.
3. Whether Donald’s adultery and participation in a transfer arguably intended to hinder potential claims barred relief under the clean-hands doctrine.

## Decision

- The Supreme Court of Pennsylvania affirmed the final decree ordering reconveyance and imposing a constructive trust.
- The Court held the evidence supported the chancellor’s finding that Theresa used threats and misrepresentations to obtain sole title, resulting in unjust enrichment.
- The Court deferred to the chancellor’s credibility-based findings because the chancellor heard and observed the witnesses and the record supported those findings.
- The Court concluded the marital difficulties did not negate a confidential relationship where the parties were still cohabiting and continuing marital relations during the period leading to the transfer.
- The Court rejected the clean-hands defense because Donald’s adultery and any intent to hinder potential litigation lacked the required immediate and necessary relation to the specific equitable relief sought.

## Legal Principles

- A constructive trust may be imposed in equity to prevent unjust enrichment where property is obtained through fraud, including threats and misrepresentations inducing a transfer.
- Appellate review of equity decrees gives substantial weight to a chancellor’s findings that depend on credibility and will not disturb them if supported by the evidence.
- A confidential relationship may exist between spouses during marriage and can support equitable scrutiny of transactions between them, even amid marital strain, depending on the factual context.
- The clean-hands doctrine bars equitable relief only when the plaintiff’s misconduct bears an immediate and necessary relation to the claim and the relief requested.

## Conclusion

The court affirmed equitable relief requiring the wife to reconvey the marital home because the husband’s transfer was fraudulently induced through threats and misrepresentations within a continuing marital relationship, and the husband’s adultery did not, on these facts, bar a constructive trust remedy.


Stauffer v. Stauffer, 465 Pa. 558 (1976)