Mauldin v. Snowden
2011 Ark. App. 630
| Ark. Ct. App. | 2011Background
- Case involves mineral rights to two tracts in Van Buren County, owned surface by Ronald E. Mauldin and Pamela D. Mauldin.
- Mauldins sued Snowden, Snowden, Florys, Cenark, Petrohawk, and Chesapeake seeking mineral ownership; bench trial resulted in denial of Mauldins’ mineral rights claims.
- Historical chain: Snowdens acquired surface and minerals in 1992; mineral deed to Cenark in 1993; Snowdens later conveyed surface rights to Florys in 1997 without mineral reservations.
- Florys conveyed two tracts to Mauldins in 2003 without mineral reservations; Cenark later conveyed Cenark’s minerals to Snowden in 2004; Snowden leased to Chesapeake in 2005 and later to JayJon, Inc. in 2006.
- Mauldins filed complaint in 2008; trial court granted reformation of deeds (1997 Snowden→Florys and 2003 Florys→Mauldins) to reserve minerals; trial court denied after-acquired title relief; Mauldins appealed.
- Trial court’s amended order in 2011 reaffirmed reformation saying mutual mistake existed; this appeal followed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether after-acquired title statute applies to mineral rights | Mauldins: statute transfers minerals upon recording of Cenark→Snowden deed. | Snowdens/Florys: reformation prevents passing minerals; statute not triggered. | Statute does not apply; reformation defeats passing of minerals. |
| Whether the trial court properly reformed deeds to reserve mineral interests | Reformation supported by mutual mistake; Mauldins seeking minerals. | Snowdens/Florys: reformation appropriate to reflect intended reservation. | Yes; reformation of both deeds upheld. |
| Whether equity supports reformation given conduct of the parties | Equities favor Mauldins due to Snowdens’ prior knowledge; lack of diligence. | Equity operates to correct mutual mistakes; Snowdens acted with misapprehension. | Equity supported; court affirmed reformation. |
| Relation back under Mason v. Jarrett after reformation | Reformation should relate back to original deed date and pass minerals via after-acquired title. | Reformation relates back, negating after-acquired title. | Reformation relates back; after-acquired title does not pass. |
Key Cases Cited
- Peterson v. Simpson, 286 Ark. 177 (1985) (recording system importance for mineral ownership)
- Mason v. Jarrett, 234 S.W.2d 771 (1950) (reformation relates back to time of deed execution)
- Lawrence v. Crafton, 2010 Ark. App. 231 (2010) (equitable reformation requires clear evidence of mutual mistake)
- Roberson Enter., Inc. v. Miller Land & Lumber Co., 700 S.W.2d 57 (1985) (reformation as correction of instrument reflecting parties’ intent)
- Omni Holding & Dev. Corp. v. C.A.G. Invs., Inc., 258 S.W.3d 374 (2007) (standard of review for bench-trial findings: clearly erroneous)