A man lost the chance to buy his parents’ farmland for $100 an acre after failing to meet their farming condition. (AI image)
A North Dakota man has lost his claim to buy his parents’ farmland for $100 an acre after the state Supreme Court ruled that he failed to meet a condition set out in their wills. It also ordered a lower court to reconsider damages for his use of the farmland between 2023 and 2025.
The court upheld the finding that Todd had not fulfilled this condition, according to the ruling dated Friday. The parents had offered their son, Todd Stramer, the option to purchase the remaining farmland at the fixed price if he returned to North Dakota and actively farmed it.
For the 2023 farming season, Todd arranged for Mike Appert, a longtime tenant of the family, to grow corn and soybeans on the land. The court also considered testimony from Appert, who had been farming for more than 35 years and worked on about 47,000 acres. The court therefore upheld the finding that Todd had not actively farmed the property within the required period.
The Elaine Stramer Irrevocable Trust paid the farming expenses and reported the profits and losses in its tax filings.
The couple’s estate planning lawyer, Charles Chapman, told the trial court that William Stramer had used the expression while referring to federal farm programmes. William replied that “anybody who knows anything about farming knows what that means”. The Supreme Court said Todd could have contributed by leasing the land or equipment at fair market value.
Appert supplied the seeds and used his own employees and equipment to plant, spray and harvest the crops. Todd did not pay rent for the farmland. Todd argued that he had taken an active role in managing the farming operation. The lower court accepted that he had contributed to its management. However, it found that he had not independently provided enough money, equipment or land for the operation. The court examined the federal Farm Service Agency’s definition of being actively engaged in farming. Under this definition, a person must contribute capital, equipment or land, along with personal labour or management. The person’s share of profits or losses must also match their contribution, and they must face a financial risk. The Supreme Court agreed with the lower court’s use of this definition. Chapman recalled asking William what active farming meant. The records showed that the family trust paid for the farming operation. Todd did not use his own money to fund it or maintain a separate business account. Appert provided the equipment, while the trust paid for its use. However, he did not do so. His interest in the farmland through the purchase option was not enough to meet the requirement. He could not validly exercise the option to buy it.
The dispute began after William and Elaine Stramer made their wills in July 2013. Their wills gave Todd the option to buy the remaining farmland for $100 an acre. William died in January 2015, and Todd moved back to North Dakota. Elaine died in November 2022. Appert had paid $233,368 in rent for 2,333.68 acres in 2022. The amount was divided into two equal payments of $116,684, one for each trust. However, the records did not clearly establish who received all the farming income between 2023 and 2025. Their parents’ wills gave Douglas an option to purchase the immediate farmyard for $100 an acre. He argued that this covered 25 acres identified in a survey completed in November 2014. Douglas had testified that the actual farmyard measured about 5.96 acres. The Supreme Court ruled that his purchase option covered 5.96 acres, not the entire 25 acres.
Because he had failed to meet the condition for buying it, the Supreme Court agreed that Todd’s occupation of the property was wrongful. The Supreme Court said the rental value of Elaine’s half was therefore $116,684 a year.
If Todd completed the purchase, he would also receive the farm machinery, equipment and the balance in the checking account, according to the offer. It said the estate was entitled to damages for the use of the land. However, the court said the full rent from the property could not be used to calculate the amount owed to Elaine’s estate. The court said compensation could be calculated using either the fair rental value of Elaine’s share or the income generated from it.
The couple had five children, Todd, Ann, Douglas, Steve and Matthew. However, he had to move back to North Dakota and actively farm the property. He also had to exercise the option within one year of the death of the surviving parent. Todd then informed the estate that he wanted to exercise his purchase option. However, his siblings challenged his claim. The dispute eventually reached the North Dakota Supreme Court, which examined whether Todd had actually been farming the property as required by his parents. The farmland was divided into two equal interests. One half belonged to the William Stramer Disclaimer Trust, while the other half belonged to Elaine’s estate. It reversed the lower court’s decision on damages and sent the matter back for the amount to be calculated. The Supreme Court also considered a separate claim by Todd’s brother Douglas, who wanted to buy land around his house. However, the court found that the survey had been prepared for a proposed purchase that included additional land for Douglas’s beekeeping business. It was not meant to identify the farmyard covered by the will.
His sister Ann sought his removal from both positions in 2023. Ann also challenged the lower court’s refusal to award compensation for Todd’s use of the farmland between 2023 and 2025. She argued that he should pay $700,104 for the three years. Her calculation was based on the $233,368 rent that Appert had paid for the farmland in 2022.
The case also involved Todd’s role in managing his mother’s estate and trust. After Elaine’s death, he became the personal representative of her estate and was named trustee of the Elaine Stramer Irrevocable Trust. The lower court removed him after finding that he had violated his duties. The Supreme Court upheld this decision. The court partly upheld and partly reversed the lower court’s decisions. It sent the case back for the judgment to be amended and for damages arising from Todd’s use of the farmland to be calculated. You use AI every day. Now get your AI Quotient. Take the AIQ test.