Buffalo Mining Co. v. Martin

267 S.E.2d 721 (1980)

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Buffalo Mining Co. v. Martin

West Virginia Supreme Court of Appeals
267 S.E.2d 721 (1980)

Facts

James and Toni Martin (defendants) owned the surface rights to a tract of land, and the Buffalo Mining Company (Buffalo) (plaintiff) held an interest in the coal beneath that land. Buffalo had obtained the mining rights from a coal lease, which had been derived from an 1890 deed that severed the mining rights from the surface estate. Buffalo operated a large mine under the Martins’ property. To ventilate that project, Buffalo needed to build electric lines on the Martins’ surface property. The Martins attempted to obstruct that construction. Buffalo sought an injunction allowing the construction. The Martins failed to introduce evidence at the trial-court level, instead arguing that the question was a purely legal one based on the reading of the language in the deed. The trial court sided with Buffalo, and the Martins appealed. The Martins argued that the trial court erred because (1) the power lines would supply power to mines not underneath their property, which was not consistent with the lease’s easement rights to surface use, and (2) the parties at the time of the 1890 deed could not have contemplated the use of power lines, so the deed did not authorize such use.

Rule of Law

Issue

Holding and Reasoning (Miller, J.)

Dissent (Harshbarger, J.)

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