No Reformation of Deeds For Successors Not in Privity

In this case, the petitioners alleged that they had a pre-existing agreement regarding the boundary line for property they acquired which pre-dated two deeds dividing and conveying the property to petitioners and to a third-party. Specifically, one deed (which was first in time) conveyed the southern tract from grantor to a third-party and one deed conveyed the northern tract to the petitioners. Petitioners then sought reformation of the first deed because of their alleged pre-existing agreement regarding the boundary line. However, the Court found that reformation of a deed is available only for parties to the deed or who are in privity (chain of title), so reformation was not available to the Petitioners because they were not parties to the first deed regarding the southern tract nor were they in the chain of title for the southern tract.

Rowland v. Quevreaux, WD83877