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In Georgia, generally, a constructive trust cannot be imposed on real property based solely on a broken verbal promise to hold or transfer the land for the benefit of another.  However, a broken verbal promise may give rise to a constructive trust if it was fraudulently made and for the purpose of obtaining title.

Source: Beware The Constructive Trust When Relying On ‘Informal’ Estate Distributions | Bryan Cave Fiduciary Litigation

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