Hoffman v. Chapman

182 Md. 208, 34 A.2d 438 (1943)



A court of equity will reform a written instrument to make it conform to the real intention of the parties when the evidence is so clear, strong, and convincing as to leave no reasonable doubt that a mutual mistake was made. Parol evidence is inadmissible to vary or contradict the terms of a written instrument, unless fraud, accident, or mistake occurred, and will admit parol evidence to reform the instrument, even though it is within the statute of frauds.


The sellers agreed to sell part of lot four to the purchasers. That part of the lot had a single dwelling on it, and the purchasers clearly understood that they were receiving only that part of the lot. The deed between the parties, however, conveyed the entire lot. The sellers filed an action in equity to reform the deed. The trial court granted the sellers relief, and the purchasers appealed the case to Court of Appeals of Maryland. The purchasers claim that the mistake was unilateral on the part of the sellers.


Should the deed of sale be reformed?




The court recognized that a lawsuit in equity for reformation was a proper remedy where an instrument did not reflect the parties' true intention and when the evidence was so clear, strong, and convincing as to leave no reasonable doubt that a mutual mistake had been made in the instrument. The court found that this was such a case. The court held that there could not have been any doubt as to which dwelling on lot four the purchasers had agreed to buy because they had lived in it for two months before the final payment was made. The court stated the mere inadvertence or negligence, especially that of the attorney who prepared the deed, did not bar the sellers from relief.

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