North Dakota Joint TenancyNorth Dakota Joint Tenancy

North Dakota Joint Tenancy

Common Law Forms of Co-ownership

Under the historical common law, there were three forms of real property co-ownership (concurrent estates):

  • tenancy by the entirety,
  • tenancy in common, and
  • joint tenancy.

See Chester H. Smith, Real Property Survey, pages 17-19, 113-120, West Publishing, 1956.

See Wilson v. Wilson, 43 Minn. 398, 45 N.W. 710 (Minn., 1890).

See Hendrickson v. Minneapolis Federal Sav. & Loan Ass’n, 161 N.W.2d 688, 690, 281 Minn. 462, 464 (Minn., 1968).

Tenancy by the Entirety

Under the historical common law, a tenancy by the entirety was a form of joint tenancy title ownership – with the added requirement of unity between a husband and a wife as one legal person.

See Chester H. Smith, Real Property Survey, page 18, West Publishing, 1956.

A tenancy by the entirety – which could exist only between a husband and a wife – operated like a joint tenancy in the sense that survivorship rights between spouses were mandatory.

See Chester H. Smith, Real Property Survey, page 18, West Publishing, 1956.

However, a tenancy by the entirety was distinguished from a joint tenancy in that:

  1. neither spouse could voluntarily transfer his or her interest, and
  2. a court partition of the title ownership of a tenancy by the entirety was not permitted.

Therefore, there was no method by which a tenancy by the entirety could be converted into a tenancy in common – other than by divorce – which destroyed the unity between a husband and a wife as one legal person.

See Chester H. Smith, Real Property Survey, pages 18, 119 West Publishing, 1956.

Minnesota Tenancy by the Entirety

In 1890, the Minnesota Supreme Court identified that the tenancy by the entirety form of real property title ownership had been abolished in Minnesota, by providing in part as follows:

An incident or property of this peculiar estate, by the entirety,

which it had in common with the estate in joint tenancy,

was the right of survivorship.

But, unlike the case of joint tenancy, neither of the parties could alien [convey real property] without the assent of the other.

The reason for the rule upon conveyances to husband and wife, as given by Blackstone, (book 2, c. 12, p. 182, Cooley’s 2d Ed.,) was:

“For, husband and wife being considered as one person in law, they cannot take the estate by moieties, (that is, each taking an undivided half of the whole estate,) but both are seised of the entirety per tout et non permy.”

It would seem as though the reason for the rule having ceased, and unity, so far as rights of property are concerned no longer existing,

  • the wife being as capable of taking and holding property as though she were unmarried, and
  • she and her husband being no more considered as one person in the law as to property,

 there could no longer be any foundation for the rule.

 And the statute has very clearly abolished that sort of tenancy; that is, by the entirety.

Wilson v. Wilson, 43 Minn. 398, 45 N.W. 710 (Minn., 1890)

The “Blackstone” referred to in the Wilson v. Wilson decision was Sir William Blackstone, an eighteenth century English jurist, judge and politician who wrote a well regarded Commentaries on the Laws of England.

Https://en.wikipedia.org/wiki/William_Blackstone, retrieved 3-06-2018.

North Dakota Forms of Co-ownership

In 1976, the North Dakota Supreme Court recognized that both the tenancy in common and joint tenancy forms of real property co-ownership were lawful in North Dakota, by providing in part as follows:

While some states have statutorily abolished the right of survivorship, our legislature has specifically recognized the estate in joint tenancy.

Our legislature has distinguished between “joint tenancy interests” and “interests in common“: . . .

Jamestown Terminal Elevator Inc. v. Knopp, 246 N.W.2d 612, 615 (N.D., 1976).

See Renz v. Renz, 256 N.W.2d 883 (N.D., 1977).

However, tenancy by the entirety was never recognized in North Dakota.

See Renz v. Renz, 256 N.W.2d 883, 884-885 (N.D., 1977), citing Schimke v. Karlstad, 87 S.D. 349, 208 N.W.2d 710 (1973), in which the Supreme Court of South Dakota pointed out that such estates did not exist in Dakota Territory, from which both States were formed.

Historical Tenancy in Common – Ownership Interests

Historically, each co-owner in a tenancy in common form of title ownership held an undivided percentage of a given class of real property ownership interests.

See Chester H. Smith, Real Property Survey, pages 18-19, 120-121, West Publishing, 1956.

See Jamestown Terminal Elevator Inc. v. Knopp, 246 N.W.2d 612 (N.D., 1976)

In other words, a tenancy in common existed when a distinct, undivided fractional share, was held by each individual owner.

See Chester H. Smith, Real Property Survey, pages 18-19, 120-121, West Publishing, 1956.

For example, if there are two tenants-in-common with respect to a real property interest, each tenant-in-common will typically own an undivided 50% of the real property interest.

The grantees in a Deed of Conveyance which creates a tenancy in common will take equal fractional interests in the property unless the Deed of Conveyance or other circumstances indicate a contrary intent.

See Chester H. Smith, Real Property Survey, pages 18-19, 120-121, West Publishing, 1956.

Each tenant in common will have the right to dispose of his or her share, or any fractional interest therein, by a Deed of Conveyance or Last Will and Testament.

See Chester H. Smith, Real Property Survey, pages 18-19, 120-121, West Publishing, 1956.

Upon the death of a tenant in common, the tenant in common’s interest in real property will descend to his or her heirs pursuant to the laws of intestate succession, in the absence of a valid disposition of the real property interest pursuant to a probated Last Will and Testament, or Transfer on Death Deed.

See Chester H. Smith, Real Property Survey, pages 18-19, 120-121, West Publishing, 1956.

Feudal Origins of Joint Tenancy

In a feudal society, a person having legal sovereignty over land – known as an overlord – offered protection to his vassals from enemies in return for allegiance, and the performance of certain duties and services.

Feudalism Favored Joint Tenancy

In a common law feudal society, joint tenancy was the favored form of title ownership, because:

  • when the overlord called upon one of his vassals to provide the required duties and services,
  • it was deemed to be a call upon all of the joint tenants with respect to a parcel of land – by reason of the fact that all of the joint tenants were seen collectively as one vassal – rather than as multiple vassals.

See Chester H. Smith, Real Property Survey, page 17, West Publishing, 1956

Common Law Joint Tenancy – Historical Four Unities Required

Under the historical common law in many jurisdictions other than North Dakota, four requirements had to be satisfied before any real property title would be recognized as a joint tenancy interest:

  1. Time – all of the joint tenants must have acquired their interests in the real property at the same time.
  2. Title Source – all of the joint tenants must have received their interests in the real property pursuant to the same Deed of Conveyance, or the same probated Last Will and Testament.
  3. Interest – all of the joint tenants must have received the same identical interest in the real property.
  4. Possession – physical possession of the real property must have been taken by at least one of the joint tenants – which would constitute the physical possession of all of the joint tenants at the same time.

See Renz v. Renz, 256 N.W.2d 883, 885 (N.D., 1977).

See Chester H. Smith, Real Property Survey, page 17, 113-114, West Publishing, 1956.

North Dakota Joint Tenancy – Four Unities Not Required

North Dakota, however, apparently never identified the four unity factors as being required in order to establish a North Dakota joint tenancy:

. . . some of the opinions of other States

  • recite the four unities (interest, title, time, and possession) which the common law required in order to establish a joint tenancy, and
  • hold that an agreement of the parties prior to divorce, or the divorce judgment, which dissolves one of the unities (usually that of possession), thereby transmutes the joint tenancy into a tenancy in common, since joint tenancy cannot exist without the existence of the four unities.

. . . Such an argument is not convincing as to North Dakota, for although we

  • have recited the Blackstonian doctrine of the four unities as a matter of history [In re Estate of Paulson, 219 N.W.2d 132 (N.D. 1974)] and
  • have otherwise quoted Blackstone on joint tenancies [Jamestown Terminal Elevator, Inc. v. Knopp, 246 N.W.2d 612 (N.D. 1976)],

 we have never held that the four unities were required in order to establish a joint tenancy under our law.

Nor should we so hold now, because

  • joint tenancy is a creature of statute in this Code State and
  • the statute, Section 47-02-06, quoted in part above, requires at the most two unities, title and perhaps time.

See Renz v. Renz, 256 N.W.2d 883, 885 (N.D., 1977).

North Dakota Joint Tenancy – No Public Policy

Unlike the presumption in some states that tenancies in common are the default form of co-ownership, it would be an overstatement to make the same claim about North Dakota title ownership law, even though North Dakota Century Code (“N.D.C.C.”) Section 47-02-08 provides in part as follows:

Every interest created in favor of several persons in their own right is an interest in common, . . . unless declared in its creation to be a joint tenancy.

Minnesota Joint Tenancy – Public Policy

In 1977, the North Dakota Supreme Court identified that the neighboring State of Minnesota had a historic policy of disfavoring joint tenancies:

This conclusion as to public policy is based on a Minnesota statute (M.S.A. § 500.19, subd. 2) providing that all grants and devises to two or more persons

“shall be construed to create estates in common, and not in joint tenancy, unless expressly declared to be in joint tenancy,”

and upon the abolition of the common-law estate by the entirety.

See Renz v. Renz, 256 N.W.2d 883, 884 (N.D., 1977).

North Dakota Joint Tenancy – Rule of Construction

In the 1977 Renz v. Renz decision, the North Dakota Supreme Court cited the rule of construction identified in N.D.C.C. Section 47-02-08, which identified:

  • when tenancies in common were to be recognized, and
  • when joint tenancies were to be recognized:

by providing in part as follows:

Thus we, too, have a statutory declaration that a conveyance to two or more persons will result in a tenancy in common unless the conveyance expressly declares the tenancy to be a joint tenancy.

But we cannot in all honesty construe this statute to be

  • an expression of hostility toward joint tenancy or
  • an expression of public policy against joint tenancy.

On the contrary, it appears to us that the statute simply represents a choice by the Legislature of a rule of construction which selects one of two possible interpretations of a provision otherwise ambiguous.

We do not believe this creates a public policy against the interpretation not selected.

Nor do we find any other expressions of hostility toward joint tenancy in our statutes or court decisions, even though many of our lawyers and judges think there should be such a hostility.

Renz v. Renz, 256 N.W.2d 883, 885 (N.D., 1977).

North Dakota Tenancy in Common – Defined

N.D.C.C. Section 47-02-08 defines the tenancy in common form of title ownership – an interest in common – in the following manner:

N.D.C.C.  47-02-08. Interest in common defined.

An interest in common is one owned by several persons

not in joint ownership or partnership.

Every interest created in favor of several persons in their own right is an interest in common,

  • unless acquired by them in partnership for partnership purposes, or
  • unless declared in its creation to be a joint tenancy.

North Dakota Joint Tenancy – Defined

N.D.C.C. Section 47-02-06 defines the joint tenancy form of title ownership in the following manner:

N.D.C.C.  47-02-06. Joint tenancy interest defined.

A joint interest is one owned by several persons in equal shares

by a title created by a single will or transfer,

  • when expressly declared in the will or transfer to be a joint tenancy, or
  • when granted or devised to executors or trustees as joint tenants.

In 1955, the North Dakota Supreme Court identified that the same definition of a joint interest was in use in 1943 in North Dakota, by providing as follows as follows:

‘A joint interest is one owned by several persons in equal shares by a title created by a single will or transfer, when expressly declared in the will or transfer to be a joint tenancy, or when granted or devised to executors or trustees as joint tenants.’

Section 47-02-06, NDRC 1943.

Kaspari’s Estate, In re, 71 N.W.2d 558, 564 (N.D., 1955).

The North Dakota Supreme Court in Kaspari’s Estate also identified the common law definition of joint tenancy, by providing in part as follows:

‘In the ancient language of the common law, joint tenants were said to hold per my et per tout or, as expressed in plain language, ‘by the moiety or half and by the whole.’

The true interpretation of this phrase seems to be that such tenants were seised of the entire estate for the purpose of tenure and survivorship, but of only a particular part or interest for the purpose of immediate alienation.’

Kaspari’s Estate, In re, 71 N.W.2d 558, 564 (N.D., 1955), citing 14 Am. Jur., Cotenancy, Sec. 8, p. 81.

‘A joint tenancy is not a testamentary disposition of property.

A joint tenancy is a present estate in which both joint tenants are seized in the case of real estate, and possessed in the case of personal property per my and per tout.

One of the characteristics of a joint tenancy is a right of survivorship between the joint tenants, if the joint tenancy is still in existence.

The right of survivorship, however, does not pass anything from the deceased joint tenant to the surviving joint tenant.’ 

Kaspari’s Estate, In re, 71 N.W.2d 558, 564 (N.D., 1955), citing Strout v. Burgess, 144 Me. 263, 68 A.2d 241, 252, 12 A.L.R.2d 939.

‘The joint tenant who survives does not take the moiety of the other tenant from him or as his successor, but takes it by right under the conveyance or instrument by which the joint tenancy was created.’

Kaspari’s Estate, In re, 71 N.W.2d 558, 564 (N.D., 1955), citing 48 C.J.S., Joint Tenancy, Sec. 1 b, p. 911.

Joint tenancy is not an estate of inheritance; a joint tenant who dies leaving a surviving tenant has no interest which he may devise.

Kaspari’s Estate, In re, 71 N.W.2d 558, 564 (N.D., 1955), citing Hoeffner v. Hoeffner, 389 Ill. 253, 59 N.E.2d 684.

North Dakota Joint Tenancy – Method of Creation

A North Dakota joint tenancy in real property can only be created pursuant to:

  • a Deed of Conveyance, or
  • a probated Last Will and Testament.

See N.D.C.C. Section 47-02-06.

See Chester H. Smith, Real Property Survey, page 113, West Publishing, 1956.

This means that a North Dakota joint tenancy interest can never be created pursuant to the North Dakota laws of intestacy.

See Chester H. Smith, Real Property Survey, page 113, West Publishing, 1956.

North Dakota Joint Tenancy – Title Standards

The Title Standards Committee of the Real Property, Probate, and Trust Section of the State Bar Association of North Dakota has adopted at least 6 North Dakota Title Standards (2017) relating to North Dakota joint tenancy interests – three of which address the severance or termination of North Dakota joint tenancy interests.

Such North Dakota Title Standards are not legislative statutes, and do not have the force and effect of governmental sanction.

Nevertheless, the North Dakota Title Standards are typically recognized by North Dakota title examiners as being a proper statement of the governing rules with respect to the issues identified therein, and are primarily intended:

  • to eliminate technical objections that do not constitute actual defects in the title and common objections that are based on misapprehension of the law and
  • to recognize, as material, certain defects that experience has shown to be often overlooked or misunderstood by title examiners.

                  North Dakota Title Standards – 2017; Introduction

Therefore, all North Dakota joint tenancy issues should be reviewed by North Dakota legal counsel in light of the North Dakota Title Standards which address such matters.

North Dakota Joint Tenancy – Nature

In 1976, the North Dakota Supreme Court further described the nature of a North Dakota joint tenancy title interest, by providing in part as follows:

A joint tenancy may be described as

  • a life estate
  • with each joint tenant having a contingent remainder in fee, the contingency being based upon survival of the other joint tenant or tenants. . . .

The right of survivorship is in

  • the whole interest conveyed by the original joint tenancy deed,
  • not merely in the deceased joint tenant’s moiety.

This concept may perhaps be clarified by referring to Blackstone:

“. . . The interest of two joint tenants is not only equal or similar, but also is one and the same.

One has not originally a distinct moiety from the other; but, if by any subsequent act (as by alienation or forfeiture of either) the interest becomes separate and distinct, the joint tenancy instantly ceases.

But, while it continues, each of two joint tenants has a concurrent interest in the whole;

and therefore, on the death of his companion, the sole interest in the whole remains to the survivor.

For the interest, which the survivor originally had, is clearly not devested by the death of his companion;

and no other person can now claim to have a joint estate with him, for no one can now have an interest in the whole, accruing by the same title, and taking effect at the same time as his own;

neither can anyone claim a separate interest in any part of the tenements, for that would be to deprive the survivor of the right which he has in all, and every part.

As, therefore, the survivor’s original interest in the whole still remains;

and as no one can now be admitted, either jointly or severally, to any share with him therein, it follows

  • that his own interest must now be entire and several and
  • that he shall alone be entitled to the whole estate (whatever it be) that was created by the original grant.”

Jamestown Terminal Elevator Inc. v. Knopp, 246 N.W.2d 612, 613-614 (N.D., 1976), citing 2 W. Blackstone, Commentaries *184-185.

The “Blackstone” referred to in the Jamestown Terminal Elevator decision was Sir William Blackstone, an eighteenth century English jurist, judge and politician who wrote a well regarded Commentaries on the Laws of England.

Https://en.wikipedia.org/wiki/William_Blackstone, retrieved 3-06-2018.

North Dakota Joint Tenancy – Survivorship

In the same 1976 Jamestown Terminal Elevator decision, the North Dakota Supreme Court identified that survivorship is an essential element of a North Dakota joint tenancy title ownership interest, by providing in part as follows:

In In Re Kaspari’s Estate, supra, 71 N.W.2d at p.564, quoting 48 C.J.S. Joint Tenancy § 1 b, p.910, this court said that the right of survivorship is the distinctive characteristic of such a tenancy.

Jamestown Terminal Elevator Inc. v. Knopp, 246 N.W.2d 612, 615 (N.D., 1976).

The North Dakota Supreme Court in Kaspari’s Estate also declared that:

. . . [the joint tenancy] property passed to the widow by right of survivorship and not by the will.

Kaspari’s Estate, In re, 71 N.W.2d 558, 564 (N.D., 1955), citing In re Mechler’s Will, 246 Wis. 45, 16 N.W.2d 373.

‘Survivorship is the distinctive characteristic of an estate in joint tenancy.’

Kaspari’s Estate, In re, 71 N.W.2d 558, 564 (N.D., 1955), citing 48 C.J.S., Joint Tenancy, Sec. 1 b, p. 910.

North Dakota Joint Tenancy – Effect of Survivorship

North Dakota joint tenancy title ownership differs from North Dakota tenancy in common title ownership in that the surviving joint tenant(s) succeeds to the real property title interests of a deceased joint tenant with whom the North Dakota joint tenancy title was shared:

A surviving joint tenant obtains the deceased joint tenant’s interest in jointly held real property,

  • not from the deceased joint tenant’s estate,
  • but by reason of the original joint tenancy deed.

Jamestown Terminal Elevator Inc. v. Knopp, 246 N.W.2d 612, 614 (N.D., 1976), citing Schlichenmayer v. Luithle, 221 N.W.2d 77,83 (N.D. 1974); In Re Kaspari’s Estate, 71 N.W.2d 558, 564 (N.D. 1955).

The surviving joint tenant does not take the interest of the deceased joint tenant;

rather, the contingent remainder vests in the survivor because the contingency (survival of the cotenant) has been met.

The deceased joint tenant had, essentially,

  • a life estate which no longer exists, 
  • a power in himself and his judgment creditor to sever which was never exercised and lapsed upon death, and
  • a contingent remainder which never vested.

Jamestown Terminal Elevator Inc. v. Knopp, 246 N.W.2d 612, 614 (N.D., 1976), citing Ziegler v. Bonnell, supra; Blackstone, supra.

Such real property survivorship rights will defeat any succession rights which may be claimed by the estate of the deceased North Dakota joint tenant with whom the North Dakota joint tenancy title ownership was shared.

See Seehafer v. Seehafer, 704 N.W.2d 841, 2005 ND 175 (2005).

By definition, survivorship rights are a necessary component of the North Dakota joint tenancy form of title ownership because all of the North Dakota joint tenants collectively constitute a single person.

See Jamestown Terminal Elevator Inc. v. Knopp, 246 N.W.2d 612, 613-614 (N.D., 1976).

See Chester H. Smith, Real Property Survey, page 17, West Publishing, 1956.

North Dakota Joint Tenancy – Undivided Ownership of the Entire Interest

Under the North Dakota joint tenancy form of title ownership, every joint tenant owns the same undivided 100% of the property interest.

See Jamestown Terminal Elevator Inc. v. Knopp, 246 N.W.2d 612, 613-614 (N.D., 1976).

See Chester H. Smith, Real Property Survey, page 114, West Publishing, 1956.

This means that an individual North Dakota joint tenant does not own an undivided percentage of the total ownership interest.

Rather, each North Dakota joint tenant is one member of a collective unit which owns the entire property interest.

See Jamestown Terminal Elevator Inc. v. Knopp, 246 N.W.2d 612, 613-614 (N.D., 1976).

See Chester H. Smith, Real Property Survey, pages 17, 114, West Publishing, 1956.

The fundamental requirements of a North Dakota joint tenancy interest is that two or more persons who are properly identified as North Dakota joint tenants, hold title to real property as though they were a single person.

See N.D.C.C. Section 47-02-06.

See Chester H. Smith, Real Property Survey, page 114, West Publishing, 1956.

North Dakota Joint Tenancy – Proof of Death

(i)      Evidentiary Options

After the death of one North Dakota joint tenant, North Dakota Title Standard #4-05 – citing the authority of N.D.C.C. § 47-19-06 – identifies that one or more of the following documents may be recorded in the County real estate records in order to clear the decedent joint tenant’s title interest in real property:

(a)        an estate tax clearance, release or order,

(b)       a death certificate, or

(c)        an affidavit.

However, N.D.C.C. § 47-19-06 fails to identify an affidavit as a statutorily authorized method of eliminating a North Dakota joint tenancy interest.

(ii)     Certified Copy of the Decedent’s Death Certificate

N.D.C.C. § 47-19-06 identifies the effect of filing a certified copy of the decedent’s death certificate in order to clear a decedent joint tenant’s title interest in real property:

In all cases of joint tenancy in lands, . . .

  • a copy of the death certificate of the joint tenant . . .
  • duly certified by any officer who is required by the laws of the state or country in which the record is made, to keep a record of the death of persons occurring within the jurisdiction of the officer,
  • may be recorded in the office of the recorder of the county in which the lands are situated.

Legal Description

The legal description of any property to which the recording of the death certificate relates must be attached to the death certificate.

Prima Facie Evidence

The certified copy of death certificate, or the record thereof in the office, or a duly certified copy of the last mentioned record, is prima facie evidence of

  • the death of the person and
  • the termination of the joint tenancy and all the estate, title, interest, and lien as was or is limited upon the life of that person.

(iii)    Affidavit Re: the Decedent’s Death

North Dakota Title Standard #18-01 – citing the authority of N.D.C.C. § 47-19-11 and  N.D.C.C. § 47-19-12 – identifies when an affidavit may be recorded in the County real estate records in order to establish:

  • the death of a decedent, and
  • the extinguishment of the decedent joint tenant’s title interest in real property.

However, N.D.C.C. § 47-19-11 and  N.D.C.C. § 47-19-12 do not contain any references to establishing the death of any person by the recording of an affidavit in the County real estate records.

Therefore, perhaps the preferred method of eliminating a North Dakota joint tenancy interest is by the recording of a certified copy of the decedent’s death certificate in the County real estate records.

Conclusion – North Dakota Joint Tenancy

North Dakota joint tenancy title ownership is distinguished from North Dakota tenancy in common title ownership by reason of the fact that the surviving North Dakota joint tenant(s) succeed to the property interests of a deceased North Dakota joint tenant with whom the joint tenancy was shared.

If you would like assistance with respect to any North Dakota joint tenancy title ownership issues, contact North Dakota attorney Gary C. Dahle, at 763-780-8390, or gary@dahlelaw.com.

Gary C. Dahle has represented clients from the countries of Canada, Norway, and Sweden, and the states of Alabama, Arizona, California, Colorado, Connecticut, Florida, Idaho, Illinois, Indiana, Iowa, Louisiana, Maine, Massachusetts, Michigan, Minnesota, Missouri, Montana, New Mexico, New York, North Carolina, North Dakota, Ohio, Oklahoma, Oregon, Tennessee, Texas, Virginia, Washington, and Wisconsin in the United States, with respect to North Dakota mineral rights and probate issues in various North Dakota Counties.

Attorneys not licensed in North Dakota are invited to refer possible North Dakota joint tenancy title ownership issues to Minnesota and North Dakota attorney Gary C. Dahle, at 763-780-8390, or gary@dahlelaw.com.

Topics of Interest – North Dakota Ancillary Probate

Topics of Interest – North Dakota Intestate Succession.

Topics of Interest – North Dakota Inheritance Laws

Topics of Interest – North Dakota Intestate Estate

Topics of Interest – North Dakota Foreign Personal Representative

Topics of Interest – North Dakota Subsequent Administration

Topics of Interest – North Dakota Mineral Rights.

Topics of Interest – North Dakota Transfer on Death Deeds

Topics of Interest – North Dakota Affidavits of Heirship

Topics of Interest – North Dakota Informal Probate

Topics of Interest – North Dakota Formal Probate

Topics of Interest – North Dakota Probate Settlements

Topics of Interest – Probating a Will Copy in North Dakota

Topics of Interest – North Dakota Probate Closing

Topics of Interest – Newly Discovered North Dakota Property

Topics of Interest – North Dakota Mineral Rights Purchase Offers

Related issues – see Minnesota Probate.

Minnesota Joint Tenancy

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Gary C. Dahle – Attorney at Law

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http://www.legis.nd.gov/general-information/north-dakota-century-code

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