The Next Step v. Redmon

The Next Step, an unincorporated association, and Jamie Redmon, an individual, both claimed title to residential real property in Minot. Both parties claimed ownership through different quitclaim deeds they alleged were executed by the prior owner of the property. Redmon alleged the quitclaim deed to The Next Step was forged. Holly Gates, a co-founder of The Next Step, asserted it was not. The Next Step moved for summary judgment, and Redmon filed a response. The district court did not immediately rule on the motion; it instructed the parties to provide supplemental briefing on the issue of whether unincorporated associations were capable of holding title to real property in North Dakota. After the parties provided their supplemental briefs, the court entered an order dismissing the case. The court held unincorporated associations are incapable of holding title to real property in North Dakota. The Next Step appealed. The Supreme Court affirmed dismissal, finding that indeed, unincorporated associations were incapable of holding title to real property. View "The Next Step v. Redmon" on Justia Law