Whitney Holding Corp. v. Terry
180 Oil & Gas Rep. 102
Wyo.2012Background
- Whitney Holding conveyed Ranchester property to Clarence and Peggy Terry via Limited Warranty Deed dated February 25, 1980, subject to Kaufmanns' prior mineral reservation and Zimmerman life estate.
- Exhibit A in the Kaufmann deed reserved one-half of all minerals to the sellers and referenced a Zimmermann life estate; Zimmerman life estate is expressly noted in Exhibit A.
- Whitney originally acquired the Ranchester property from Kaufmanns, with Kaufmanns reserving one-half of the minerals; Whitney later conveyed to Terrys and did not retain minerals.
- Terrys recorded mineral leases and affidavits reflecting termination of the Zimmerman life estate; Whitney did nothing to claim mineral interests prior to suit.
- Terrys filed a Complaint to Quiet Mineral Title; Whitney answered, raising statute of limitations and other defenses; trial yielded an ambiguity ruling by the district court.
- District court found the Limited Warranty Deed ambiguous, admitted extrinsic evidence, and quieted title in Terrys; Whitney appeals.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is the Limited Warranty Deed ambiguous? | Whitney argues the reservation language is clear and unambiguous. | Terrys contend the deed language is ambiguous when read with related instruments. | Deed is ambiguous. |
| Was extrinsic evidence properly admitted to interpret the deed? | Whitney asserts extrinsic evidence is not admissible to resolve unambiguous language. | Terrys argue extrinsic evidence is admissible to discern intent and meaning. | Extrinsic evidence properly admitted. |
| Did the court correctly interpret the deed to determine mineral ownership? | Whitney claims the reservation language clearly reserves minerals to Whitney. | Terrys contend the reservation refers to Kaufmanns and reflects Terrys' mineral ownership subject to life estate. | Deed interpreted to show Whitney did not reserve minerals; Terrys own one-half. |
| Is Terrys' quiet title action barred by the statute of limitations for reformation? | Whitney argues the action is reform; thus barred by a ten-year limit. | Terrys say action is quiet title, not reform; statute does not bar. | Not barred; action is quiet title, not reformation. |
Key Cases Cited
- Mullinnix LLC v. HKB Royalty Trust, 126 P.3d 909 (Wyo. 2006) (de novo review of legal conclusions in contract disputes)
- Powder River Ranch, Inc. v. Michelena, 103 P.3d 876 (Wyo. 2005) (standard of review for contract interpretation; credibility not reweighed)
- Harber v. Jensen, 97 P.3d 57 (Wyo. 2004) (foundational standard for appellate review of factual findings)
- Shaffer v. WINhealth Partners, 261 P.3d 708 (Wyo. 2011) (requirement to give effect to each contract term; ambiguity governs parol evidence use)
- Ecosystem Resources, LC v. Broadbent Land & Resources LLC, 158 P.3d 685 (Wyo. 2007) (contract interpretation focuses on parties' intent and four-corners language)