Four Season's Healthcare Center, Inc., et al. v. Linderkamp, et al., 837 N.W.2d 147 (N.D. Sup. Ct. 2013)

(married couple owned farm and leased farmland to a son; son claimed the existence of an oral agreement that parents would compensate him for improvements as part of the price he would pay for eventual purchase of the farm; farm eventually sold to son at less than fair market value and son claimed he had made approximately $100,000 in improvements; parents then entered nursing home and resided their until their deaths; at time of their deaths approximately $93,000 remained in unpaid nursing home bills; nursing home sued to set aside transfer of farm as fraudulent conveyance; trial court set aside sale and held that son was personally responsible under state law for parents' unpaid nursing home bill; on appeal, court held that sale of farm was a fraudulent conveyance and remanded to trial court on issue of personal responsibility for debt of parents; appellate court determined that evidence was absence of oral agreement or of improvements to property, and that sale of farm made at time when parties reasonably believed that parents would need nursing home care; appellate court also held that trial court erred in holding son personally liable for parents' debt until determining liability of other parents' other children).