Pennsylvania Joint Property & Tenancy by the Entirety

A mother and her son were deeded a house using a legal term that's literally impossible between people who aren't married. It still worked out exactly as they intended.

Clear designation required, unless you're married

Pennsylvania recognizes joint tenancy with right of survivorship when the instrument creating it clearly designates that arrangement. Without a clear designation, a tenancy in common is presumed by law instead — a co-owner's share goes through probate. There's one built-in exception: for ownership arrangements between a husband and wife, Pennsylvania presumes a tenancy by the entirety by law, without needing the deed to spell it out.

A deed that used the wrong legal term entirely

A real Pennsylvania Superior Court case shows how far courts will go to honor a deed's actual intent, even over its literal wording. In 1972, a couple conveyed real estate to Raymond Reigle and his mother, Gertrude — describing them as taking title "as tenants by the entireties." Raymond and Gertrude were mother and son, not married to each other, which makes that specific form of ownership legally impossible for them. When Gertrude died in 1990, her estate argued the deed should default to a tenancy in common among her heirs. The court disagreed: because the "tenants by the entireties" language unambiguously expressed an intent to create survivorship — survivorship being the defining feature of that form — the deed instead created a joint tenancy, the co-ownership form that most closely matched that expressed intent. Raymond took full title to the property by operation of law.

A different kind of challenge: was the intent real at all?

Not every dispute over Pennsylvania joint tenancy is about ambiguous wording. In one Pennsylvania county case, an estate's executrix argued that a deed's clear joint tenancy language shouldn't control, because the joint tenancy had actually been set up in an attempt to shield the property from Medicaid estate recovery — meaning, she argued, the property remained a probate asset in substance despite what the deed said. This kind of challenge reflects a real tension in Pennsylvania practice: a technically valid joint tenancy deed can still be contested if someone argues the parties never genuinely intended the survivorship consequences that come with it.

The traditional four unities still matter

Pennsylvania joint tenancy still depends on the traditional four unities: interest, title, time, and possession. Each joint tenant needs an equal interest, acquired through the same instrument, at the same time, with an equal right to possess the whole property. An action that's inconsistent with maintaining these unities — such as one owner unilaterally conveying away their share — can sever the joint tenancy as to that share, converting it into a tenancy in common. Simply filing a partition action, without more, generally doesn't by itself manifest the irrevocable intent needed to sever.

No shortcut around any of this

Because Pennsylvania has no transfer-on-death deed, joint tenancy and tenancy by the entirety remain the two main tools for keeping real estate out of probate without a trust. See our explanation of why Pennsylvania has no TOD deed for the fuller picture, including what Pennsylvania does allow for other kinds of assets.

Pennsylvania joint property — frequently asked questions

What does Pennsylvania require to create a joint tenancy in real estate?

The instrument creating the joint tenancy must clearly designate that ownership arrangement. Without that clear designation, a tenancy in common is presumed instead, except between spouses, where a tenancy by the entirety is presumed by law.

What happened in the Pennsylvania case about a mother and son deeded as "tenants by the entireties"?

A mother and her adult son, who were not married to each other, were deeded property "as tenants by the entireties" in 1972. The Pennsylvania Superior Court held that while that specific form is legally impossible for unmarried people, the language clearly expressed an intent to create survivorship, so it created a joint tenancy instead — and the son took full title when his mother died.

Is tenancy by the entirety automatic for married couples in Pennsylvania?

Yes. Pennsylvania presumes real estate owned by a husband and wife is held as tenants by the entirety by law, with an automatic right of survivorship, without needing the deed to expressly state that arrangement.

Can a Pennsylvania joint tenancy be challenged as a sham to avoid Medicaid recovery?

Yes, this type of challenge does arise in Pennsylvania courts. An estate representative may argue that a joint tenancy designation on a deed does not reflect the parties' actual intent and was instead an attempt to shield the property from Medicaid estate recovery, keeping it as a probate asset in substance.

What are the four unities required for a Pennsylvania joint tenancy?

Interest, title, time, and possession — each joint tenant must hold an equal interest, acquired through the same instrument, at the same time, with an equal right to possess the whole property. An action inconsistent with these unities can sever the joint tenancy.

This page provides general guidance only and is not legal advice. Figures and rules are based on Pennsylvania statute and published Pennsylvania court decisions, verified per our methodology. Confirm how a specific deed is actually titled with the county Recorder of Deeds or a licensed Pennsylvania attorney before acting.