Sheila Singleton, et al. Missouri Cases

Lillian Singleton sought to reform a property deed, executed with her deceased husband J.C., claiming a scrivener's error mistakenly included their son Dennis as a remainder interest holder in Tract I, contrary to their estate planning intent. The circuit court reformed the deed, finding Lillian's testimony credible and applying the principle that equity may reform a voluntary instrument. The Missouri Supreme Court reversed, holding that the circuit court erroneously declared and misapplied the law because the deed contained a unilateral mistake, which, absent fraud, deception, or bad faith, will not be reformed.