Amoco Production Co. v. United States

In 1942, the Federal Farm Mortgage Corporation (FFMC) conveyed an interest in certain land to Hyrum and Florence Newton. The original 1942 deed was lost or destroyed, and the only surviving version of the deed was that recorded with the county. The recorded version showed that FFMC conveyed the entire interest to the Newtons with no reservation of mineral interests. Despite this version, the parties disputed whether this conveyance included the mineral interests. In 1957, FFMC conveyed to the United States government (defendant) the mineral interest it believed it held in the Newtons’ property. In 1960, the Newtons conveyed their interest in the subject property to a family corporation. In 1972, the family corporation, believing that it held the mineral rights in the land, conveyed such rights to Amoco Production Company (Amoco) (plaintiff). Amoco sued the United States to quiet title to the mineral rights in the land. At trial, Amoco introduced the recorded version of the deed, which showed that FFMC conveyed its entire interest to the Newtons, with no mineral reservation. The United States sought to present evidence that FFMC’s routine practice was to retain a mineral interest in lands it conveyed during the relevant period. The United States also presented other evidence, including a photocopy of a conformed copy of the deed found in Bureau of Land Management (BLM) files. Based on Federal Rule of Evidence 1005 (Rule 1005), the trial court excluded all the government’s evidence related to the contents of the 1942 deed. The court ruled that the availability of the recorded copy of the deed precluded all other evidence of the deed’s contents. The court then granted Amoco summary judgment. The United States appealed.