Canova Land & Investment Co. v. Lynn
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The Supreme Court affirmed the judgment of the circuit court dismissing Appellant's complaint seeking to quiet title to certain property, holding that a deed restriction for the use of a particular church was not an unreasonable restraint on alienation.
In 1875, Edna and Levi Lynn executed a deed granting one acre of land to the Woodbine Baptist Church. Woodbine used the land until 2006, when its trustees gifted it to a Virginia corporation. The corporation received a loan in 2007, and the bank's title search of the property did not disclose the 1875 deed. When the corporation defaulted on the loan, Canova Land and Investment Company acquired title to the property at a foreclosure sell but did not take possession of the property. Canova later brought suit to quiet title to the property, arguing that a reverter clause in the 1875 deed, providing that if the property was not used for purposes expressed in the deed it should revert to the grantors or their heirs, should be voided as an unreasonable restraint on alienation. The circuit court dismissed the complaint, upholding the 1875 deed as valid. The Supreme Court affirmed, holding that the reverter was a restraint on use and not unreasonable.
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