Bryan S. Perez, et al. v. Mary Pelentay, Individually and as Trustee of the Quach Living Trust
1. Whether the Fourteenth Amendment's Due Process Clause permits a State to permanently extinguish recorded fee-simple title through a trust-and estate proceeding resolved on summary judgment when the statutory vehicle and pleadings did not provide notice reasonably calculated to apprise deed holders that vested inter vivos title would be adjudicated and terminated, and when the deed holders were denied a meaningful opportunity to litigate quiet title before deprivation.
2. Whether the Fourteenth Amendment's Due Process Clause is violated when a state court applies an unexpected and indefensible reworking of settled deed-construction principles—including the four-corners rule and the rule construing ambiguities against the grantor—to invalidate facially unconditional inter vivos deeds based on post-execution extrinsic statements attributed to a deceased grantor.
Whether the Fourteenth Amendment's Due Process Clause permits a State to permanently extinguish recorded fee-simple title through a trust-and-estate proceeding resolved on summary judgment without notice reasonably calculated to apprise deed holders that vested inter vivos title would be adjudicated and terminated, and whether due process is violated when a state court applies an unexpected reworking of settled deed-construction principles to invalidate facially unconditional inter vivos deeds based on post-execution extrinsic statements