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?

No. A deed is only valid if the grantor intends to convey ownership at the time of delivery.

In this case, the deed was invalid. The nephew gets nothing. 

Affirmed

Delivery of the deed must include delivery of title & outright ownership at the time of delivery