PADDYAKER v. Griffith
2011 OK CIV APP 97
| Okla. Civ. App. | 2011Background
- Paddyakers sue Griffith and Newcastle Public Works Authority seeking to quiet title to 75 acres and recover water rights allegedly conveyed in 1987.
- Griffith granted water rights and a permanent easement to Authority via a 1987 Water Rights Agreement and related documents.
- Authority obtained a groundwater permit from the Oklahoma Water Resources Board in 1987; Paddyakers did not object or appeal.
- Paddyakers claimed the 1987 permit constitutes a final determination of ownership of the water rights, creating a bar to their challenge.
- Defendants argued the Water Resources Board proceedings were administrative disputes not affecting private title; the district court had jurisdiction to adjudicate title.
- Trial court dismissed for lack of subject matter jurisdiction and on statute-of-limitations grounds; appellate review was de novo.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does the district court have jurisdiction to adjudicate title in this quiet title action? | Paddyaker contends the district court is the proper forum for title determination. | Griffith/Authority argue the Board's 1987 permit order precludes title challenges as collateral attack. | District court has jurisdiction to adjudicate title; dismissal for lack of jurisdiction reversed in part. |
| Is the quiet title claim barred by the statute of limitations? | Equitable nature of quiet title allows pursuit despite passage of time. | No, the Board order and intervening timing bar the claim. | Statutes of limitation do not bar the quiet title action. |
| Are the conversion and unjust enrichment claims barred by limitations? | N/A (not favored). | Claims are subject to two-year (or fifteen-year) limitations depending on characterization and are barred. | Conversion and unjust enrichment are barred by the applicable statute of limitations. |
| What is the proper disposition of the case given these rulings? | Remand for further proceedings on title with proper jurisdiction. | Affirm dismissal of non-title claims and limit to any viable relief. | Affirm in part (limitations on non-title claims) and reverse in part (jurisdiction to quiet title); remand for proceedings consistent with title jurisdiction. |
Key Cases Cited
- Rogers v. Quiktrip Corp., 230 P.3d 853 (Okla. 2010) (de novo review appropriate on appeal from dismissal)
- Conoco, Inc. v. State Dep't of Health, 651 P.2d 125 (Okla. 1982) (timeliness of administrative review is jurisdictional)
- Red Rock Petroleum Co., Inc. v. City of Choctaw, 689 P.2d 1286 (Okla. 1984) (adjudication of title is proper in district court)
- Samson Resources Co. v. Oklahoma Corp. Comm'n, 859 P.2d 1118 (Okla. 1993) (agency bodies with limited jurisdiction cannot determine vested property interests)
- Hester v. Watts, 218 P.2d 641 (Okla. 1950) (quiet title actions immune from general statute of limitations)
- Alfrey v. Richardson, 231 P.2d 363 (Okla. 1951) (equitable defense considerations in quiet title actions)
- Sullivan v. Buckhorn Ranch Partnership, 119 P.3d 192 (Okla. 2005) (genuine issues preclude summary judgment in quiet title context)
- The Water Resources Bd. v. Ricks Exploration Co., 695 P.2d 498 (Okla. 1984) (Board regulates groundwater use but does not determine private title)