CALVERT v. SWINFORD, 2016 OK 104

Sisters Lisa Calvert and Teresa Roper sold real property in Noble County but intended to retain mineral interests; deeds were executed without reserving minerals.
Deeds were filed of record; approximately twelve years later the sisters discovered the alleged omission.
Plaintiffs sued for reformation and negligence against multiple parties, including Randee Koger (Kansas attorney) and his law firm Bremyer & Wise, LLC, who prepared the deeds.
Defendants moved for summary judgment asserting the claims were time-barred by the applicable statutes of limitations.
The trial court granted summary judgment for the attorney and law firm, ruling that the grantors received constructive notice when the deed was filed of public record and that the limitations periods had run.
The Oklahoma Supreme Court retained the appeal to decide whether a grantor’s cause of action accrues when the deed is filed with the county clerk; the Court affirmed the trial court, following its related decision in No. 114,957.

Issue	Plaintiff's Argument	Defendant's Argument	Held
When does the statute of limitations begin for a grantor’s negligence/reformation claim based on a deed that failed to reserve minerals?	Limitations had not necessarily begun because factual disputes exist about when plaintiffs discovered the mistake and whether constructive notice was effective.	Limitations began when the deed was filed of public record because filing gives constructive notice and starts the accrual period.	The Court held accrual begins when the deed is filed with the county clerk; claims were time-barred.

(No official-reporter-cited Oklahoma Supreme Court opinions were included as bluebook-style reporter citations in this opinion.)