Ida-Therm, LLC v. Bedrock Geothermal, LLC, 293 P.3d 630

Bell Deed (1946) reserved all oil, gas, and minerals in the Bell Property to grantor(s).
Dispute centers on whether the reservation includes geothermal resources.
Plaintiffs (Ida-Therm’s predecessors) contend geothermal not included; Bedrock contends geothermal included.
District court held mineral estate includes geothermal resources and granted Bedrock summary judgment.
Ida-Therm appeals, arguing mineral language is ambiguous and geothermal is not included; court reverses.
Judgment reversed; geothermal resources are not included; C.C. Mann’s successors own geothermal rights; costs awarded to Ida-Therm.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does the Bell Deed reservation include geothermal resources?	Ida-Therm argues ‘mineral’ does not include geothermal.	Bedrock argues the reservation includes geothermal resources.	Geothermal resources not included; reservation ambiguous leading to grantor-favorable interpretation.
Is the term ‘mineral’ ambiguous, and how should it be interpreted?	Ambiguity exists; extrinsic evidence may illuminate intent.	Term is unambiguous and should be interpreted as severing mineral estate.	‘Mineral’ is ambiguous; interpret narrowly in favor of the grantee (Ida-Therm) and construe against the grantor.

C & G, Inc. v. Rule, 135 Idaho 763 (Idaho 2001) (ambiguous deed interpretation; canons of construction apply)
Gardner v. Fliegel, 92 Idaho 767 (Idaho 1969) (shadow of ambiguity; parol evidence aiding intent)
Latham v. Garner, 105 Idaho 854 (Idaho 1983) (easement language ambiguous; multiple reasonable interpretations)
Kinney v. Keith, 128 P.3d 297 (Colo. App. 2005) (mineral term varies by jurisdiction; ambiguity depends on context)
Northern Nat. Gas Co. v. Grounds, 441 F.2d 704 (10th Cir. 1971) (policy concerns and certainty in mineral definitions; forcefulness of definitions)