Co-ownership

Lakeside Village is a 530-unit condominium development in Culver City consisting of 12 separate three-story buildings whose residents share common lobbies, hallways, laundry, and trash facilities. In April 1978 the developer recorded a declaration of covenants, conditions, and restrictions that included the provision that no animals, defined to mean dogs and cats, livestock, reptiles, or poultry, shall be kept in any unit. Plaintiff Natore Nahrstedt purchased a unit in January 1988 and moved in with her three cats, which she kept entirely inside the unit. When the Lakeside Village Condominium Association learned of the cats it demanded their removal and levied successive monthly fines against Nahrstedt. Nahrstedt then filed suit against the Association, its officers, and two employees seeking declaratory relief that the pet restriction was unreasonable as applied to her indoor cats, invalidation of the assessments, damages for invasion of privacy and emotional distress, and injunctive relief. The complaint alleged that the cats were noiseless, created no nuisance, and had not damaged any portion of her unit or the common areas, and it incorporated by reference the grant deed, the declaration, and the condominium plan. The Association demurred to the complaint on the ground that the restriction was reasonable as a matter of law. The trial court sustained the demurrer as to every cause of action and dismissed the complaint. A divided Court of Appeal reversed the judgment of dismissal, concluding that Nahrstedt had stated a claim for declaratory relief because the reasonableness of enforcing the restriction against her particular cats presented a factual question. The dissenting justice in the Court of Appeal maintained that the recorded restriction should be treated as presumptively valid under the law of equitable servitudes. On the Association's petition the Supreme Court granted review.

In 1988, the Internal Revenue Service assessed $482,446 in unpaid income tax liabilities against Don Craft for his failure to file federal income tax returns for the years 1979 through 1986. At that time, Don Craft and his wife, respondent Sandra L. Craft, owned a piece of real property in Grand Rapids, Michigan, as tenants by the entirety. After notice of the federal tax lien was filed, the Crafts jointly executed a quitclaim deed purporting to transfer Don Craft's interest in the property to Sandra Craft for one dollar. When Sandra Craft later attempted to sell the property, a title search revealed the lien. The IRS agreed to release the lien to allow the sale on the condition that half of the net proceeds be held in escrow pending determination of the Government's interest. Sandra Craft then brought an action in the United States District Court for the Western District of Michigan to quiet title to the escrowed proceeds. The District Court granted summary judgment to the Government. On appeal, the United States Court of Appeals for the Sixth Circuit held that the tax lien did not attach to the property under Michigan law and remanded for consideration of the Government's fraudulent conveyance claim. On remand, the District Court found that the conveyance itself was not fraudulent but that the use of nonexempt funds to pay the mortgage constituted a fraudulent act, and it awarded the IRS a share of the proceeds. The Sixth Circuit affirmed that determination on the lien issue as law of the case. The Supreme Court granted certiorari to consider whether Don Craft had a separate interest in the entireties property to which the federal tax lien attached.

In late May 2001, respondent Scott Randolph and his wife Janet separated when Janet left their marital residence in Americus, Georgia, and went to stay with her parents in Canada, taking their son and some belongings. In July 2001, Janet returned to the Americus house with the child. On the morning of July 6, 2001, Janet complained to the police that after a domestic dispute her husband had taken their son away, and when officers reached the house she told them that her husband was a cocaine user whose habit had caused financial troubles. Shortly after the police arrived, Scott Randolph returned and explained that he had removed the child to a neighbor's house out of concern that his wife might take the boy out of the country again; he denied cocaine use, and countered that it was in fact his wife who abused drugs and alcohol. One of the officers asked Scott Randolph for permission to search the house, which he unequivocally refused. The sergeant then turned to Janet Randolph for consent to search, which she readily gave. She led the officer upstairs to a bedroom that she identified as Scott's, where the sergeant noticed a section of a drinking straw with a powdery residue he suspected was cocaine. Sergeant Murray left to get an evidence bag and called the district attorney's office, which instructed him to stop the search and apply for a warrant. When he returned, Janet Randolph withdrew her consent. The police took the straw to the police station along with the Randolphs. After obtaining a search warrant, they returned and seized further evidence of drug use, leading to Scott Randolph's indictment for possession of cocaine. He moved to suppress the evidence as the product of a warrantless search unauthorized by his wife's consent over his express refusal. The trial court denied the motion. The Georgia Court of Appeals reversed, and the Georgia Supreme Court affirmed. The United States Supreme Court granted certiorari.