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Butler v. Charles Powers Estate

Supreme Court of Pennsylvania
65 A.3d 885 (2013)


Facts

In 1881, Charles Powers conveyed a tract of land to the predecessors in interest of John and Mary Butler (plaintiffs) and reserved “one-half [of] the minerals and Petroleum Oils” in the land. In 2009, the Butlers sued the Charles Powers Estate (Estate) (defendants) and its heirs and assigns (defendants) to quiet title in the land, including all the minerals and petroleum oils beneath the property. William and Craig Pritchard, the rightful heirs to the Estate, filed a motion for a declaratory judgment, seeking a ruling that the deed reservation included one-half of all natural gas located beneath the surface of the land. The  Estate claimed that the reservation, by using the term “minerals,” included natural gas within a shale formation below the surface of the land. The Butlers claimed that the deed did not reserve any natural gas, because the deed did not explicitly state that natural gas was being reserved. The Susquehanna County Court of Common Pleas found in favor of the Butlers. The superior court reversed. The Butlers appealed.

Rule of Law

Issue

Holding and Reasoning (Baer, J.)

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