The Supreme Court of North Dakota has refused to create an exception to the general rule that an unincorporated association may not hold title to real estate under state law. It has denied a request by a nonprofit association to make an exception to recognize a deed the association claimed it received from the former owner. ( The Next Step v. Redmon , Supreme Ct., ND, No. 20150333, 5/26/16. ) The Next Step claimed title pursuant to a quitclaim deed from the former owner dated 2009 and recorded in 2014. An individual claimed title under a quitclaim deed from the same person dated and recorded in 2013. The Next Step filed an action to quiet title and filed a motion for summary judgment. The...