Board of Education of Minneapolis v. Hughes Supreme Court of Minnesota, 1912. Facts: In May 1906, L.A. Hughes (defendant) bought a lot of land from Carrie Hoerger. Hughes sent his money and a deed to Hoerger with a copy of a deed to be executed and returned to him. The name of the grantee was left blank, but Hoerger signed and returned the deed. Hughes then filled his name in as grantee, and recorded the deed on December 16, 1910. In April 1909, Duryea & Wilson also received from Hoerger a quitclaim deed for the lot. This deed was recorded on December 21, 1910. On November 19, 1909, Duryea & Wilson conveyed the land to the Board of Education (plaintiff) by warranty deed, which deed was recorded on January 27, 1910. Procedural History: The Board of Education brought suit to determine who owned the title to the land. The trial court determined that the Board of Education was the proper owner. Hughes appealed. Issue: (1) Does delivery of a blank deed, with the understanding that the name of the grantee is to be written in, constitute valid delivery of title? (2) May a subsequent purchaser of property who records his deed first take valid title where the previous recipient fails to record the title? Holding: (1) Yes. Delivering a deed that does not include the name of a grantee is a nullity until the point where the grantee’s name is filled in. Where the recipient of the deed has the actual or implicit authority to fill in the name of the grantee, the delivery becomes valid at the point where the name is filled in. Here, Hughes had the implicit authority from Hoerger to fill in his name as the grantee of the property, curing the nullity of the original conveyance and making the deed effective. (2) Yes. If a piece of real property is conveyed to multiple parties, the first to duly record his title has superior rights to the property. At the time that Hughes recorded his deed, there was recorded a transfer of the property from Duryea & Wilson to the Board of Education, but no recording of the transfer from Hoerger to Duryea & Wilson. Thus, the record did not reflect that Duryea & Wilson had any valid title to convey to the Board of Education. Hughes therefore lacked constructive notice that the property had previously been conveyed, and he was a subsequent purchaser in good faith. Because Hughes recorded his title before Duryea & Wilson completed the chain of title (which would have perfected the conveyance to the Board of Education), Hughes’s title is superior. The judgment of the trial court is reversed.