Rosengrant v. Rosengrant

• Rosengrant = a retired couple that lived in Oklahoma
• Rosengrant = a nephew of the retired couple who comes to take care of their farm
• In June 1972, the couple granted the farm to their nephew by signing a deed
• The plan was for the nephew to record the deed after the passing of the couple
• The nephew was told that he could have retrieved the deed earlier
• The couple were supposed to own the farm until their deaths
• The couple died in 1974 & 1978
• Next, the nephew recorded the deed after 1978

• Shortly afterwards, other Rosengrants sued the nephew
• The relative claimed that the deed to the nephew was void because it was improperly delivered & violated the Statute of Wills
• The nephew lost for failure of proper delivery of the deed

Is a deed, executed during a grantor's life but intended to convey land after the grantor's death, a valid means of making such a transfer?