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PropertyConcurrent ownership

Riddle v. Harmon

Court of Appeal of the State of California · Decided February 25, 1980 · Core case

Full citation

Riddle v. Harmon, 102 Cal. App. 3d 524 (1980).

VerifiedQuotes, pinpoints and citation checked word for word against the opinion; facts checked against the opinion before publication. October 20, 2026.

Jack C. Riddle

surviving husbandplaintiff and respondent

Valerie Lee Parish Harmon, as Executrix

executrix of the wife's estatedefendant and appellant

The parties: Jack C. Riddle v. Valerie Lee Parish Harmon, as Executrix.

Brief

Facts

Mr. and Mrs. Riddle bought a parcel of real estate and took title as joint tenants. A joint tenancy carries a right of survivorship, so when one joint tenant dies, the survivor takes the whole. Several months before her death, Mrs. Riddle hired an attorney to plan her estate. After reviewing the documents, he advised her that the property was held in joint tenancy and would pass to her husband when she died. She was distressed by this news. She asked that the joint tenancy be ended so that she could leave her interest by will. The attorney prepared a grant deed in which Mrs. Riddle granted to herself an undivided one-half interest in the property. The deed stated that its purpose was to terminate the joint tenancies between her and Jack C. Riddle, her husband. The attorney also prepared a will that disposed of her interest in the property. Mrs. Riddle signed both the grant deed and the will on December 8, 1975. She died 20 days later. No third person took title at any point in the transaction.

Issue

Can a joint tenant unilaterally end a joint tenancy by a deed conveying her interest from herself as joint tenant to herself as tenant in common, or must she convey through a third-party intermediary, called a strawman?

Holding

Mrs. Riddle's grant deed, conveying her interest from herself as joint tenant to herself as tenant in common, severed the joint tenancy without a strawman. The trial court's judgment quieting title in her husband was therefore reversed.

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