MANUSOS v. Skeels

The principal issue in this case is whether someone who is not party to a deed may nevertheless obtain its reformation. Plaintiff contends that, when defendants acquired their property from a third party, the deed was supposed to have included an easement for her benefit. She argued that, because defendants were aware of her interest, the deed should be reformed to reflect it. The trial court agreed and reformed the deed to include an easement for plaintiffs benefit. Defendants appeal, arguing that, because plaintiff was neither a party to the deed nor in privity with any party to the deed,…