Davidson Land Co., LLC v. Davidson
2011 WY 29
| Wyo. | 2011Background
- In 1982, Daniel and Chester Davidson partitioned their ranch by cross-conveying parcels, allocating a railroad right-of-way through parcels 3-4 to Chester and 7-8 to Daniel.
- The 1982 Agreement stated that if the right-of-way was abandoned, the land within it would be conveyed to the respective adjacent owner.
- Daniel later acquired the entire right-of-way from UPRR via a quitclaim deed to Earlene in 1996; Chester’s successors allege this breached the agreement.
- Daniel’s successors obtained a summary judgment and quieted title in parcels 3-4 based on the UPRR quitclaim deed, contrary to Chester’s successors’ claims.
- The Wyoming Supreme Court reversed, holding the 1982 Agreement unambiguously required Daniel’s successors to convey any interest they acquired from UPRR in parcels 3-4 to Chester’s successors.
- The Court concluded UPRR’s quitclaim can be interpreted as abandonment of the right-of-way and that the contract required specific performance to vest title in Chester’s successors.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the district court misread contract intent? | Chester's successors: contract language unambiguous and transfers occur. | Daniel's successors: district court properly interpreted the deeds and ownership. | The contract is unambiguous; Chester’s successors prevail. |
| Does estoppel by deed bar after-acquired title? | Estoppel by deed applies to prevent retroactive title claims. | Doctrine does not apply here; specific performance governs. | Estoppel by deed does not apply; specific performance governs. |
| May quiet title sua sponte based only on a quitclaim without proof of fee ownership? | Quiet title should reflect the contract-based intent to convey. | Quiet title may be granted where valid quitclaim supports ownership. | Quiet title cannot be the sole remedy; contract-based relief (specific performance) is proper. |
Key Cases Cited
- M & M Auto Outlet v. Hill Inv. Corp., 2010 WY 56 (Wyoming) (contract interpretation governs summary judgment standard)
- Ecosystem Res., L.C. v. Broadbent Land & Res., L.L.C., 2007 WY 87 (Wyoming) (consider surrounding circumstances in contract intent)
- R.C.R., Inc. v. Rainbow Canyon, Inc., 978 P.2d 581 (Wyoming) (interpretation of contracts and accompanying instruments)
- Stansbury v. Heiduck, 961 P.2d 977 (Wyoming) (deed passes only the described interest; implied scope limits apply)
- York v. James, 62 Wyo. 184 (Wyoming) (burden to trace title when parties share a common grantor)
- Hall v. Perry, 2009 WY 83 (Wyoming) (contract interpretation and integrated documents rule)