Zayka v. Giambro

In Zayka v. Giambro, 32 Mass. App. Ct. 748, 751, 594 N.E.2d 894 (1992), the Appeals Court noted that application of estoppel by deed to a quitclaim deed is particularly compelling where . . . the claim against the title is made by someone such as the grantor's daughter/grantee's sister who bases her claim on direct descent by blood from the grantor. . . . The case might stand differently had there been an intervening bona fide purchaser who had no notice of the purported conveyance of the locus by the father to her brother. Id. at 753.