Bale v. Allison

¶1 — Robert E. Fletcher used a quitclaim deed to gift his Winthrop cabin to his nephews, John and Robert G. Fletcher.1 John and Robert appeal the trial court’s determination that the failure to recite consideration invalidated the deed. We conclude the deed is valid because it met all statutory requirements and no recital is required to effectively gift real property. Accordingly, we reverse the judgment awarding title to Denny and Allen Bale. On cross appeal, the Bales challenge the trial court’s use of the clear, cogent, and convincing standard of proof to find that the Bales failed to…