William Davidsonv.Lindfield Holdings, Llc
Lindfield Holdings brought a quiet-title action to cancel a warranty deed that William Davidson had executed purporting to transfer Lindfield’s Snellville property to himself. A special master found that Davidson lacked authority to sign the deed, and the trial court cancelled it, quieted title in Lindfield, and dismissed Davidson’s counterclaims and third-party claims as moot. The Court of Appeals of Georgia affirmed the title ruling because evidence showed that Davidson’s authority to act for Lindfield had been withdrawn before he executed the deed. But the court held that the special master’s title findings did not resolve Davidson’s separate claims that Lindfield and others had fraudulently induced him to work without agreed compensation or had been unjustly enriched. Those claims fell outside the special master’s quiet-title jurisdiction and were not moot. The court also held that the conventional quiet-title claim properly went to a special master without a jury, while the unresolved non-title claims were not subject to that statutory jury-trial restriction. The judgment was affirmed in part, reversed in part, and remanded.
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