The Mt. Morris Sportsmen's Assoc. v. Boyers, A.
The Mt. Morris Sportsmen's Assoc. v. Boyers, A. No. 506 WDA 2016
| Pa. Super. Ct. | Mar 23, 2017Background
- The Mt. Morris Sportsmen’s Association (Association) and descendants of William F. Boyers (Defendants) dispute ownership of surface and oil & gas rights under a 101.5-acre tract in Greene County, PA.
- Chain of title: 1924 deed reserved 3/5 of oil & gas to the Mason grantors while conveying surface interests as joint tenants to William H. and Sarah Mason; Sarah died 1933 and her share passed by survivorship and intestacy.
- William H. Mason conveyed (1934) his surface interests to the Boyerses while expressly reserving the 3/5 oil & gas reservation from 1924; this resulted in the Boyerses holding a 9/10 surface interest and a 1/2 oil & gas interest.
- In 1947 William F. Boyers conveyed to the Maxons but expressly reserved “all the undivided two-fifths interest in all the oil and gas rights,” leaving Boyers with a 2/5 oil & gas interest; the Maxons later conveyed to the Association (1957), which thus held a 1/10 oil & gas interest and 9/10 surface.
- In 2014 the Association’s president executed a quitclaim deed purporting to convey the Association’s oil & gas interest to Defendants; the Association sued to quiet title and void that quitclaim as unauthorized.
- The trial court voided the quitclaim for lack of corporate authorization and granted summary judgment to the Association; the Superior Court reversed as to the subsurface interests, holding Defendants (as successors to William F. Boyers) own an undivided 2/5 oil & gas interest and the Association owns 1/10.
Issues
| Issue | Association's Argument | Defendants' Argument | Held |
|---|---|---|---|
| Whether the 1947 deed reserved a 2/5 oil & gas interest in favor of William F. Boyers (thus passing to Defendants) or conveyed those rights to the Association via later transfers | The Association claimed title to a 3/5 oil & gas interest based on earlier reservations and the quitclaim | Defendants argued the 1947 deed expressly reserved a 2/5 oil & gas interest to William F. Boyers, which was never conveyed and therefore passed to them | The court held the 1947 deed unambiguously reserved a 2/5 oil & gas interest to William F. Boyers, which remained with his successors (Defendants) while the Association holds 1/10 |
| Validity of the 2014 quitclaim deed executed by the Association president | The Association sought to void the quitclaim as unauthorized and therefore ineffective | Defendants relied on the quitclaim to claim Association’s oil & gas interest | The court agreed the quitclaim was void for lack of proper corporate approval; it did not convey Association rights |
| Proper construction of the chain-of-title deeds (1924, 1934, 1947, 1957) and allocation of surface vs. subsurface estates | The Association urged interpretation consistent with its title to surface and a larger share of subsurface rights | Defendants urged construction giving effect to specific reservations (noting the 1947 2/5 reservation) and to intestacy/survivorship results | The court applied deed-construction principles, gave effect to explicit reservations and survivorship language, and apportioned surface and oil & gas interests accordingly |
Key Cases Cited
- Gilbert v. Synagro Cent., LLC, 131 A.3d 1 (Pa. 2015) (standards for appellate review of summary judgment)
- Consolidation Coal Co. v. White, 875 A.2d 318 (Pa. Super. 2005) (deed-construction principles and intent of parties)
- In re Estate of Quick, 905 A.2d 471 (Pa. 2006) (joint tenancy with right of survivorship and survivorship effect)
- Riccelli v. Forcinito, 595 A.2d 1322 (Pa. Super. 1991) (presumption against joint tenancy; survivorship valid when deed expresses it)
- Stewart v. Chernicky, 266 A.2d 259 (Pa. 1970) (definition and effect of a quitclaim deed)
- Scientific Living, Inc. v. Hohensee, 270 A.2d 216 (Pa. 1970) (corporate conveyance void without requisite approval)