Equitable Reformation of Easement Deeds to Correct Misnamed Trust Grantors and Erroneous Legal Descriptions Without Protecting Non–Bona Fide Purchasers

1. Introduction

This Lake Delhi access dispute turned on a deceptively technical question with major practical consequences: whether an Iowa district court, sitting in equity in a quiet title action, may reform a recorded easement deed that is plainly defective—both because it names the wrong trust as grantor and because its legal description does not reach the river—when the deed’s stated purpose and the parties’ actual agreement were to provide waterfront access.

The plaintiffs, Mark and Stacey Fink, purchased Lots 19 and 20 and sought to quiet title and stop their neighbors, Donald and Linda Lawson, from using a well-worn path across those lots to reach the Maquoketa River. The Lawsons owned Lot 21 and had relied on a 2002 “Easement and Agreement” intended to allow access “on foot or by vehicle” to the river. But the easement documents contained multiple errors. The district court concluded it lacked authority to reform the instrument and largely ruled for the Finks. The Supreme Court of Iowa reversed, holding reformation is available on these facts and directing the district court to correct the deed.

2. Summary of the Opinion

Applying de novo review in the equitable quiet title posture, the court concluded:

• Error was preserved because reformation was raised in resistance to summary judgment, in a motion under Iowa Rule of Civil Procedure 1.904(2), and again at trial; the district court ruled on it repeatedly.
• Reformation is available because the deed’s purpose clause plainly expressed river access intent, the parties’ long-term conduct confirmed shared understanding, and the defects were correctable mistakes in the written instrument.
• Third-party protection did not bar reformation because the Finks had notice of the recorded easement and knew the recorded description did not match the actual well-worn access route; they were not bona fide purchasers unfairly harmed by reformation.

The Supreme Court vacated the court of appeals decision, reversed the district court judgment, and remanded with instructions to reform the easement deed by (1) correcting the grantor to “Mary L. Becker, as Trustee for the Larry D. Becker Trust,” and (2) correcting the legal description to match the path the Lawsons used since 2002 to reach their dock.

3. Analysis

A. Precedents Cited and Their Role

1) Standard of review and appellate method in equity

• Rouse v. Union Township: cited for the proposition that quiet title proceedings are equitable, supporting de novo review.
• Hora v. Hora (quoting Struve v. Struve): frames what “de novo” means in Iowa—decide anew on preserved issues, but still give weight to district court credibility assessments.

These cases set the court’s posture: it was not confined to the district court’s legal conclusions about the availability of reformation. Because the case is equitable, the Supreme Court could independently determine whether the record proved mutual mistake and whether equity could supply the remedy.

2) Issue preservation

• Meier v. Senecaut: supplies the baseline rule that issues must be raised and decided below to be reviewed on appeal.

The court used Meier v. Senecaut to reject the Finks’ threshold argument. The repeated raising and rejection of reformation— including via Iowa Rule of Civil Procedure 1.904(2)—made this a cleanly preserved legal issue.

3) Iowa reformation doctrine: burden, grounds, and limits

• In re Guardianship & Conservatorship of Jorgensen: cited for the burden (“clear, satisfactory, and convincing proof”) and the general grounds (fraud, deceit, duress, or mutual mistake), with reference to Iowa R. App. P. 6.904(3)(k).
• Merle O. Milligan Co. v. Lott: the court’s central Iowa authority for reformation where the writing fails to express the parties’ agreement due to mistake, inadvertence, or accident; emphasizes the mistake must be in reducing an agreed deal to writing, not in making the deal itself.
• Wellman Sav. Bank v. Adams: clarifies the function of reformation—courts do not change the agreement; they change the instrument to conform to the real agreement.
• Orr v. Mortvedt: supplies an important limitation—reformation will not be ordered when it prejudices innocent third parties.

Together, these authorities supplied the doctrinal test the district court failed to apply correctly. The Supreme Court treated the deed’s errors as classic “instrument-drafting” failures (scrivener’s error/mutual mistake), not as an impermissible judicial rewriting of the deal.

4) Deed interpretation and “polestar” intent

• Nichols v. City of Evansdale (quoting Skoog v. Fredell): “the intent of the grantor is the polestar” in interpreting deeds.

The court relied heavily on this intent-first framing. Notably, it found the intent was not speculative: the easement deed itself stated the purpose (“access…to the Maquoketa River”). That purpose clause became a key anchor for concluding the mismatched legal description was erroneous and reformable.

5) Scrivener’s error and correcting misnamed parties (including trust entities)

• Coleman v. Coleman: cited as Iowa support for reforming an instrument containing a scrivener’s error.
• Out-of-state authorities supporting reformation where a party is misnamed/omitted, including:
  • Sound Around, Inc. v. Hialeah Last Mile Fund VII LLC
  • Bates v. Alfred F. Steiner Co.
  • Berg v. Carlstrom
  • Connor & Murphy, Ltd. v. Applewood Vill. Homeowners' Ass'n
  • Wittingham, LLC v. TNE Ltd. P'ship
  • Myers v. Town of Milton

A particularly consequential feature of this opinion is its acceptance—under “unique facts”—that reformation may correct a misnamed grantor trust, effectively aligning the deed with the actual entity holding title to the servient estate. The court acknowledged the conceptual risk that “to change the parties to an agreement is to change the agreement itself,” but cabined its holding by emphasizing the unusual alignment of powers and identity between the trusts and trustees.

6) Correcting erroneous legal descriptions that fail to match intended property

• Out-of-state decisions approving reformation where the description fails to capture the property intended, including:
  • Lawrence v. Barnes
  • Massey v. Lewis (quoting Brimm v. McGee)
  • JPMorgan Chase Bank, N.A. v. Gau
  • Dyke v. Alleman
• Restatement (Second) of Contracts § 155: cited for the general rule allowing reformation for mutual mistake in the content/effect of a writing, limited by the rights of good faith purchasers for value.

These authorities reinforced the court’s conclusion that rewriting a land description is not beyond equity’s power when the deed’s words do not capture the land the parties intended to burden/benefit. The Supreme Court effectively treated the legal description’s failure to reach the river (and its unusability due to the deck/embankment alignment) as objective indicators of mistake, not an invitation to invent a new bargain.

B. Legal Reasoning

1) Why reformation (and not merely interpretation) was required

The problem was not ambiguity resolvable by ordinary deed construction; it was a mismatch between (a) the deed’s stated purpose and intended effect and (b) the deed’s operative legal description and named grantor. The described strip did not reach the river and was not usable; the grantor trust did not own the servient parcels. Interpretation could not supply missing geography or correct title ownership. Only reformation could make the written instrument reflect the parties’ actual agreement.

2) Mutual mistake and scrivener’s error supported by conduct and document text

The court treated two defects as reformable mistakes in reducing the deal to writing:

• Misnamed grantor: Mary Becker signed as trustee of the wrong trust, even though she was co-trustee of the trust that owned Lots 19 and 20 and could act independently and dispose of trust property. The court characterized this as a scrivener’s error.
• Erroneous legal description: the description did not accomplish the expressed purpose of river access and did not match the longstanding, unchallenged use of the “well-trodden path” to the water, evidencing a mutual mistake about the writing’s content/effect.

A key evidentiary move in the court’s reasoning was its reliance on the nearly two-decade period during which the Lawsons used the path “without incident.” That history functioned as practical construction of the parties’ understanding: had the Beckers not intended such access, they likely would have objected, blocked, or redefined the route.

3) The third-party limitation did not apply because the Finks had notice of infirmity

Drawing on Orr v. Mortvedt and the Restatement’s good-faith purchaser limitation, the court concluded reformation would not “prejudice” protected third parties here. The decisive factual predicate was notice: the Finks knew before purchase that (1) a recorded easement existed and (2) its recorded description did not track the actual access path. In the court’s view, that knowledge precluded bona fide purchaser protection and made reformation equitable.

4) Remedy was specific and cabined

Rather than ordering a general “do-over,” the court prescribed precise corrective actions on remand:

• Change the named grantor to “Mary L. Becker, as Trustee for the Larry D. Becker Trust.”
• Replace the legal description with one that “conform[s] to the path the Lawsons have used since 2002.”

This is notable because the court did not merely declare an easement exists; it directed reformation of the recorded instrument itself, reinforcing that the equitable remedy is to correct the document, thereby stabilizing the land records going forward.

C. Impact

1) Doctrinal significance in Iowa

The opinion meaningfully clarifies Iowa reformation practice in real-estate instruments by:

• Confirming that reformation can correct not only internal terms but also (on these facts) a misidentified grantor trust, treating it as a scrivener’s error when authority and intent are clear.
• Confirming courts may reform an easement’s legal description when it objectively fails to achieve the deed’s stated purpose and does not reflect the parties’ agreement.
• Emphasizing the good faith purchaser limitation: purchasers with notice of the easement and its infirmities cannot defeat reformation by invoking record-title technicalities.

2) Practical implications for conveyancing, title work, and litigation strategy

• Drafting and closing: Trust-owned land transactions require careful verification of title-holding entity and signatory capacity. This case illustrates that errors may be curable, but only through expensive litigation and proof burdens.
• Title examination: Survey results that reveal a recorded easement does not “work on the ground” (e.g., doesn’t reach the water) are not merely curiosities; they can be red flags that a court may later reform the instrument consistent with purpose and historical use.
• Litigation: Parties disputing a defective recorded easement should treat reformation as a primary equitable claim/defense, develop evidence of mutual mistake (purpose clauses, negotiations, longstanding use), and address bona fide purchaser status early.

3) Limits and cautions embedded in the opinion

The court itself cautioned that “not every trust or corporate entity will be in the same position,” and that courts should exercise caution before “changing the parties” to a deed. That caveat signals a narrow path for future litigants: the more the “wrong entity” differs in powers, ownership, or trustee authority, the less likely reformation will be available.

4. Complex Concepts Simplified

Reformation (vs. interpretation)

Interpretation explains what unclear language means. Reformation changes the written document because it was written incorrectly and fails to express the real agreement (e.g., wrong entity named; wrong metes-and-bounds description). Reformation is an equitable remedy requiring a high proof standard.

Mutual mistake and scrivener’s error

A mutual mistake occurs when both parties share the same mistaken belief about what the written document says or does. A scrivener’s error is a drafting/clerical mistake (for example, inserting the wrong trust name) that misstates what was intended.

Servient estate and dominant estate

An easement benefits one parcel (the dominant estate) and burdens another (the servient estate). Here, Lot 21 benefited; Lots 19 and 20 were burdened.

Bona fide purchaser (good faith purchaser for value)

A bona fide purchaser is someone who buys for value without notice of competing rights or defects. Equity is reluctant to reform instruments if doing so would unfairly harm such purchasers. The court held the Finks were not in that protected category because they knew of the recorded easement and its mismatch with the actual path.

5. Conclusion

This decision establishes a clear Iowa rule with significant real-world bite: when an easement deed unmistakably expresses an intent (here, river access), but drafting errors misname the grantor trust and misdescribe the easement’s route, an Iowa court sitting in equity may reform the instrument to reflect the actual agreement—so long as the proponent meets the “clear, satisfactory, and convincing” burden and reformation does not prejudice a bona fide purchaser.

By ordering reformation to correct both the grantor identity and the legal description to match longstanding use, the Supreme Court prioritized substance over technical failure in the land records—while simultaneously emphasizing that this power is fact-dependent and should be exercised cautiously, especially where changing named parties could alter, rather than reveal, the true bargain.