after-acquired title doctrine (District of Columbia) · Go Syfert
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after-acquired title doctrine in District of Columbia

5 District of Columbia opinions name it 1 courts 1992–2013 0 in the last five years

The cases below were cited by District of Columbia courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (6)

CaseFollowedCited
Miller-Long v. John Hanson Savings & Loan, Inc.green
dcd · 1987 · cited in 3 District of Columbia opinions naming this issue, 1992–2009
2 sentences

2009The doctrine of after-acquired title “holds that ‘if a grantor purports to transfer ownership of real property to which he lacks legal title at the time of transfer, but subsequently acquires legal title to the property, the after-acquired title inures, by operation of law, to the benefit of the grantee.’ ” Douglas v. Lyles, 841 A.2d 1, 5 (D.C.2004) (quoting M.M. & G., Inc. v. Jackson, 612 A.2d 186, 190 (D.C.1992)); see Miller-Long v. John Hanson Sav. & Loan, Inc., 676 F.Supp. 298, 299-300 (D.D.C.1987) (noting that District of Columbia long ago adopted doctrine of after-acquired title) (citing

2004Further guidance on the general principle that one can validly contract to sell that which he does not yet own comes from the doctrine of after-acquired title, which holds that “if a grantor purports to transfer ownership of real property to which he lacks legal title at the time of transfer, but subsequently acquires legal title to the property, the after-acquired title inures, by operation of law, to the benefit of the grantee.” M.M. & G., Inc. v. Jackson, 612 A.2d 186, 190 (D.C.1992) (quoting Miller-Long v. John Hanson Savings & Loan, 676 F.Supp. 298, 299-300 (D.D.C.1987)).

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Douglas v. Lylesgreen
dc · 2004 · cited in 3 District of Columbia opinions naming this issue, 2009–2013
2 sentences

2011“The doctrine of after-acquired title holds that if a grantor purports to transfer ownership of real property to which he lacks legal title at the time of the transfer, but subsequently acquires legal title to the property, the after-acquired title inures, by operation of law, to the benefit of the grantee.” Id. at 190 ; see also Ackerman v. Abbott, 978 A.2d 1250, 1254 (D.C.2009); Douglas, supra, 841 A.2d at 5 .

2011“The doctrine of after-acquired title holds that if a grantor purports to transfer ownership of real property to which he lacks legal title at the time of the transfer, but subsequently acquires legal title to the property, the after-acquired title inures, by operation of law, to the benefit of the grantee.” Id. at 190 ; see also Ackerman v. Abbott, 978 A.2d 1250, 1254 (D.C.2009); Douglas, supra, 841 A.2d at 5 .

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M.M. & G., Inc. v. Jacksongreen
dc · 1992 · cited in 3 District of Columbia opinions naming this issue, 2004–2011
2 sentences

2011“The doctrine of after-acquired title holds that if a grantor purports to transfer ownership of real property to which he lacks legal title at the time of the transfer, but subsequently acquires legal title to the property, the after-acquired title inures, by operation of law, to the benefit of the grantee.” Id. at 190 ; see also Ackerman v. Abbott, 978 A.2d 1250, 1254 (D.C.2009); Douglas, supra, 841 A.2d at 5 .

2009The doctrine of after-acquired title “holds that ‘if a grantor purports to transfer ownership of real property to which he lacks legal title at the time of transfer, but subsequently acquires legal title to the property, the after-acquired title inures, by operation of law, to the benefit of the grantee.’ ” Douglas v. Lyles, 841 A.2d 1, 5 (D.C.2004) (quoting M.M. & G., Inc. v. Jackson, 612 A.2d 186, 190 (D.C.1992)); see Miller-Long v. John Hanson Sav. & Loan, Inc., 676 F.Supp. 298, 299-300 (D.D.C.1987) (noting that District of Columbia long ago adopted doctrine of after-acquired title) (citing

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Ackerman v. Abbottgreen
dc · 2009 · cited in 2 District of Columbia opinions naming this issue, 2011–2013
2 sentences

2013Under that doctrine, “if a grantor purports to transfer ownership of real property to which he lacks legal title at the time of transfer, but subsequently acquires legal title to the property, the after-acquired title inures, by operation of law, to the benefit of the grantee.” Ackerman v. Abbott, 978 A.2d 1250, 1254 (D.C.2009) (internal quotations omitted); see also Douglas v. Lyles, 841 A.2d 1, 4 (D.C.2004) (“[A]t common law a presumptive heir can assign to a third party as ephemeral an interest as his or her expectancy interest.”); Columbian Carbon Co. v. Right, 207 Md. 203 , 114 A.2d 28, 3

2011“The doctrine of after-acquired title holds that if a grantor purports to transfer ownership of real property to which he lacks legal title at the time of the transfer, but subsequently acquires legal title to the property, the after-acquired title inures, by operation of law, to the benefit of the grantee.” Id. at 190 ; see also Ackerman v. Abbott, 978 A.2d 1250, 1254 (D.C.2009); Douglas, supra, 841 A.2d at 5 .

22
Columbian Carbon Co. v. Kightgreen
md · 1955 · cited in 1 District of Columbia opinions naming this issue, 2013–2013
2 sentences

2013Under that doctrine, “if a grantor purports to transfer ownership of real property to which he lacks legal title at the time of transfer, but subsequently acquires legal title to the property, the after-acquired title inures, by operation of law, to the benefit of the grantee.” Ackerman v. Abbott, 978 A.2d 1250, 1254 (D.C.2009) (internal quotations omitted); see also Douglas v. Lyles, 841 A.2d 1, 4 (D.C.2004) (“[A]t common law a presumptive heir can assign to a third party as ephemeral an interest as his or her expectancy interest.”); Columbian Carbon Co. v. Right, 207 Md. 203 , 114 A.2d 28, 3

2013Under that doctrine, “if a grantor purports to transfer ownership of real property to which he lacks legal title at the time of transfer, but subsequently acquires legal title to the property, the after-acquired title inures, by operation of law, to the benefit of the grantee.” Ackerman v. Abbott, 978 A.2d 1250, 1254 (D.C.2009) (internal quotations omitted); see also Douglas v. Lyles, 841 A.2d 1, 4 (D.C.2004) (“[A]t common law a presumptive heir can assign to a third party as ephemeral an interest as his or her expectancy interest.”); Columbian Carbon Co. v. Right, 207 Md. 203 , 114 A.2d 28, 3

11
Campbell v. Butlergreen
okla · 1988 · cited in 1 District of Columbia opinions naming this issue, 2009–2009
1 sentence

2009See Campbell v. Butler, 770 P.2d 7, 10 (Okla.1988) (holding that two grantees claiming under the after-acquired-title doctrine pursuant to conveyances before the grantor was vested in legal title took priority according to first in time principle where equities were equal); 31 C.J.S.

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Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in District of Columbia. Read the followed side critically anyway.

Statutes the citing opinions construe

DC § D.C. Code § 20-105 (4)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

TX 21 (1945–2026) LA 14 (1958–2025) CA 9 (1995–2025) IL 8 (1984–2019) NM 7 (1994–2019) MS 7 (1973–2019) DC 5 (1992–2013) OK 4 (1981–2005) AL 4 (1985–2012) FL 3 (2015–2017) ND 3 (2011–2015) WA 2 (1918–2008) CO 2 (1983–2021) UT 2 (2012–2013) MI 2 (2007–2025)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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