426 S.W.3d 488
Ark. Ct. App.2013Background
- The Longing Family Revocable Living Trust and Longing Hunting Club own surface but seek mineral title to 220 acres in Van Buren County.
- Snowdens acquired surface title and undivided one-half minerals in 1994; later conveyed minerals to Cenark in 1994 and surface to Tri.Con in 1995.
- In 2000–2004, transfers chain culminated in Longings acquiring property interest, with Cenark later conveying mineral interests back to Snowdens in 2004.
- Longings filed suit in 2008 asserting after-acquired-title rights and a 2004 Cenark-to-Snowdens mineral deed; lis pendens was filed contemporaneously.
- Circuit court held the 1995 Tri.Con deed conveyed no minerals due to mutual mistake and reformation; deferred to that reform to nullify after-acquired title.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether mutual mistake justifies reformation of the 1995 deed | Longings claim mining rights were intended to be reserved. | Snowdens argue no intent to convey minerals; reform to reflect reservation is proper. | Yes; reformation granted due to mutual mistake. |
| Whether after-acquired-title statute applies when deed reformation occurs | Mineral title passes to Longings by after-acquired title. | Reformation negates after-acquired title since minerals were not conveyed. | Not applicable; reformation eliminates minerals passing under the statute. |
| Whether lis pendens bars equitable relief of reformation | Lis pendens has effects beyond notice; may bar defenses. | Lis pendens only provides notice and does not bar equitable relief. | No merit; lis pendens did not bar reformation. |
| Whether reformation was properly pled and admissible | Reformation issues were raised via pleadings or proof. | No fatal defect; pleading in answer/cross-claim permitted; Rule 15(b) conformity applies. | Properly pled and admissible; reformation was a valid preliminary step. |
| Whether Tri.Con’s dissolution affected validity of defenses | Dissolution should not impact third-party defense and reform efforts. | Dissolution does not bar defense; corporate existence can continue for defense purposes. | Not fatal to defendants' positions; defense allowed. |
Key Cases Cited
- Mauldin v. Snowden, 2011 Ark. App. 630 (Ark. App. 2011) (mutual mistake guiding reform in mineral-title chain)
- Stalter v. Gibson, 379 S.W.3d 710 (Ark. 2010) (de novo review of reformation with factual findings)
- Lambert v. Quinn, 798 S.W.2d 448 (Ark. App. 1990) (mutual mistake defined; equitable reform principles)
- Realty Investment Co. v. Higgins, 91 S.W.2d 1030 (Ark. 1936) (pleading and pleading amendments for reform)
- Troupe v. Ancrum, 225 S.W. 9 (Ark. 1920) (no specific prayer for reformation required)