North Dakota Supreme Court Denies Man Option to Buy Farmland for $100 an Acre

A North Dakota man lost his claim to buy family farmland for $100 an acre after the state Supreme Court ruled he failed to meet active farming conditions set in his parents’ wills, The Times of India reported.

William and Elaine Stramer drafted their wills in July 2013, offering their son Todd the option to purchase the remaining acreage at the fixed price of $100 an acre. The provision required Todd to return to North Dakota, actively farm the land, and exercise the option within one year of the surviving parent’s death.

The parents had five children: Todd, Ann, Douglas, Steve, and Matthew. William Stramer died in January 2015, prompting Todd to move back to the state. Elaine Stramer died in November 2022, after which Todd informed the estate he intended to exercise the purchase option.

Under the terms, a successful purchase included the farm machinery, equipment, and checking account balance. However, Todd’s siblings challenged the claim. They argued he had not actually farmed the property as required by the July 2013 wills.

For the 2023 farming season, Todd arranged for longtime tenant Mike Appert to grow corn and soybeans on the land. Appert supplied the seeds, employees, and equipment, while the Elaine Stramer Irrevocable Trust paid the operating expenses and reported profits and losses.

Todd did not pay rent or maintain a separate business account for the operation. The North Dakota Supreme Court examined the federal Farm Service Agency definition of actively engaged in farming, which requires capital, equipment, or land contributions alongside personal labor or management, plus financial risk.

The estate planning lawyer, Charles Chapman, told the trial court that William Stramer used that exact expression when discussing federal farm programs. Chapman recalled asking William what active farming meant, to which William replied that “anybody knows anything about farming knows what that means”, according to court records.

Following Elaine’s death, Todd became the personal representative of her estate and trustee of the family trust. His sister Ann sought his removal in 2023 after alleging he violated his duties, a removal the Supreme Court upheld.

Ann also sought $700,104 in compensation for Todd’s use of the farmland between 2023 and 2025. Her calculation relied on the $233,368 rent that Appert paid for 2,333.68 acres in 2022.

The Supreme Court ruled Todd’s occupation wrongful because he failed to meet the purchase condition, making the estate entitled to damages. Because the land was split between the William Stramer Disclaimer Trust and Elaine’s estate, the court found the rental value of Elaine’s half was $116,684 annually. The justices reversed the lower court’s damages decision and sent the case back for recalculation.

In a separate claim, brother Douglas sought to buy land around his house for $100 an acre under a will option. Douglas argued the option covered 25 acres identified in a November 2014 survey meant for a beekeeping business.

The Supreme Court found the survey was prepared for a broader proposed purchase rather than the farmyard defined in the will. Because Douglas testified the actual farmyard measured about 5.96 acres, the court limited his purchase option to those 5.96 acres and returned the case for judgment amendments.

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