John Davis & Co. v. Cedar Glen No. Four, Inc

In John Davis & Co. v. Cedar Glen No. Four, Inc. (1969) 75 Wn.2d 214, the appellants challenged the validity of a quitclaim deed transferring real property to a corporation. The appellants argued that the deed was void because it was executed and recorded prior to the date the corporation filed its articles of incorporation, i.e., prior to the date the corporation became a legal entity. (Id., 450 P.2d at p. 170.) The Supreme Court of Washington rejected the appellants' argument. The court stated: "Although it is true as a general rule that a deed is void if the named grantee is not a legal entity, the facts of this case fall within an exception to the rule. A deed to a corporation made prior to its organization, is valid between the parties. Title passes when the corporation is legally incorporated. This is particularly true as against one who does not hold superior title when the corporation goes into possession under the deed." (John Davis, supra, 450 P.2d at p. 170.)