In re Estate of Koeferl, 2013 WI App 13 (Wisc. Ct. App. Dec. 18, 2012)

(decedent bought farm with co-habitator and took title as "husband and wife, as survivorship marital property"; upon decedent's death, estate argued that deed ambiguous because decedent and co-habitator never married; court determined that state law (Wis. Stat. Sec. 700.19) applied which specifies that creation of joint tenancy determined by intent expressed in document of title, instrument of transfer or bill of sale, and that if "husband and wife" specified in document, then joint tenancy results; no language in deed expressed intent to not create joint tenancy; joint tenancy created).