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MATTER OF VADNEY

Court of Appeals of the State of New York (1994) | 83 N.Y.2d 885; 634 N.E.2d 976; 612 N.Y.S.2d 375

3 min read

TL;DR: A mother deeded property to herself and her son without specifying the tenancy type. The court permitted reforming the deed to a joint tenancy, finding clear evidence of her intent and a lawyer's drafting error, thereby overcoming the statutory presumption of a tenancy in common.

Legal Significance: Establishes that the statutory presumption for a tenancy in common can be overcome by clear and convincing extrinsic evidence of a grantor's intent to create a joint tenancy, particularly when a scrivener's error is proven.