Janet and Frank Mandeville were married in 1975 and remained married until Janet died in 2002, after a battle with breast cancer. The Mandevilles acquired two properties during their marriage, their home in Macomb County and a parcel of property in Ogamaw County. They owned both properties as tenants by the entirety. Accordingly, by the right of survivorship inherent in a tenancy by the entirety, both properties passed to Frank upon Janet’s death. 

In the last decade of their marriage Frank was often out of the country for extended periods. Specifically, he was absent for the 18 months preceding Janet’s death. During this period, he did not try to call Janet or otherwise communicate with her, even though he knew she was seriously ill. He did not attend her funeral. In Frank’s absence, Janet maintained the properties and was responsible for paying the taxes, insurance, and mortgage. She was cared for by her sister, Susan Tkachik. In the months before she died, Janet executed a trust and will that stated her intent to disinherit her husband and leave everything to her mother. She tried to defeat the right of survivorship in the real estate by transferring her interest in them to her mother by a quitclaim deed. 

In November 2003, Tkachik filed suit on behalf of the estate to effectuate Janet’s intent to disinherit Frank. She claimed the Mandevilles should be considered tenants in common with regard to their real property and Frank should not obtain full ownership of the properties. Tkachik later amended her petition to seek contribution from Frank for the expenses Janet incurred in maintaining the property before her death. What is Frank’s ownership interest in the properties, if any? Is he liable for contribution?