Drake v. McNair

Summary

The District of Columbia Court of Appeals affirmed dismissal of Sherry Miles St. Claire Drake’s fraud and negligent misrepresentation claims concerning the transfer of property from an estate-related transaction to a trust beneficiary. The court held that public land records provided inquiry notice sufficient to trigger the statute of limitations and that the parties’ Settlement Agreement independently barred the claims. The court also held that considering the public records did not convert the motion to dismiss into a motion for summary judgment.

Holdings

1. The trial court properly considered the recorded Substitute Trustee's Deed and Confirmatory Substitute Trustee's Deed without converting the motion to dismiss into a motion for summary judgment because Drake referred to the deeds in her pleadings and they were public records.
2. The claims were barred by the three-year statute of limitations because the recorded deeds supplied inquiry notice of the alleged injury, its cause, and evidence of wrongdoing more than three years before Drake filed suit.
3. The incorporation and release provisions of the Settlement Agreement barred Drake's claims because she failed to allege fraud sufficient to invalidate the agreement or make reliance on omitted representations reasonable.
4. The court did not decide the res judicata issue because the statute of limitations and Settlement Agreement independently disposed of all claims.

Questions Presented

1. Whether the trial court was required to convert the Rule 12(b)(6) motion into a Rule 56 summary-judgment motion because it considered recorded deeds and other public records.
2. Whether Drake's fraud and negligent misrepresentation claims were barred by the applicable three-year statute of limitations because she was on actual or inquiry notice of the alleged wrongdoing more than three years before filing suit.
3. Whether the incorporation and release provisions of the 1998 Settlement Agreement barred Drake's claims, including her contention that the agreement was procured by fraud.
4. Whether res judicata barred the claims.

Disposition

affirmed