Wright, P. v. Misty Mountain Farm, LLC
125 A.3d 814
| Pa. Super. Ct. | 2015Background
- In 1950 Fred and Jeanetta Buck (grantors) deeded land to Robert and Marjorie Wright (grantees) but included an exception reserving “all rights in oil, gas and minerals” to the Bucks, citing a June 16, 1949 oil & gas lease.
- The 1949 lease granted Conn and Anglin oil and gas rights for ten years and as long as production continued; the record suggests it ended by 1971, after which Wright family members repeatedly leased subsurface rights to third parties.
- In 2010 the Bucks’ successor (Shirley Matthews, administratrix) conveyed the subsurface rights to Misty Mountain Farm, LLC and others; Patricia Wright (successor to the Wright grantees) sued for declaratory judgment claiming she owns the subsurface rights.
- The trial court denied preliminary objections and judgment on the pleadings but later granted summary judgment to the Misty Mountain parties; Wright appealed.
- Central legal question: whether the 1950 deed’s oil/gas/minerals clause was an exception (retaining title in the Bucks and their successors) or a time-limited reservation that would vest in the Wrights upon expiration of the 1949 lease.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether law-of-the-case barred reconsideration at summary judgment | Wright: prior denials of prelim. objections/motion on the pleadings resolved issue in her favor | Misty Mountain: trial judge may revisit own pretrial rulings at summary judgment | Court: No violation; judge may reconsider her pretrial rulings |
| Whether the 1950 deed’s oil/gas/minerals clause vested subsurface rights in Wrights after 1949 lease expired | Wright: clause referenced the 1949 lease term; when that lease expired, the exception ended and rights vested in grantees | Misty Mountain: clause is an exception leaving title in grantors (Bucks) and thus passed to their successors | Court: Clause is an exception (not an exception-to-exception); Bucks retained title; Misty Mountain owns subsurface rights |
| Whether parol evidence / factual dispute precluded summary judgment | Wright: intent of parties creates a factual dispute needing resolution | Misty Mountain: deed language is unambiguous; interpretation is a legal question | Court: Deed language unambiguous; no genuine issue of material fact; summary judgment proper |
Key Cases Cited
- Ralston v. Ralston, 55 A.3d 736 (Pa. Super. 2012) (distinguishes exceptions from exceptions-to-exceptions; explains when excepted rights may vest in grantee)
- Silvis v. Peoples Natural Gas Co., 126 A.2d 706 (Pa. 1956) (language "reserve" construed as exception where grantor retained preexisting title; no words of inheritance needed)
- Wysinski v. Mazzotta, 472 A.2d 680 (Pa. 1984) (when deed language is clear, courts ascertain intent from the words used and parol evidence is barred)
- Petrina v. Allied Glove Corp., 46 A.3d 795 (Pa. Super. 2012) (standard of appellate review for summary judgment)