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Hauck v. Crawford

Supreme Court of South Dakota
62 N.W.2d 92 (1953)


Hauck (plaintiff), a farmer with an eighth-grade education, owned a large farm. D.W. Crawford (defendant) and two other men approached Hauck to discuss the lease of Hauck’s farm for oil and gas operations. Hauck agreed to lease his property. One of the men prepared the paperwork, told Hauck where to sign, and indicated that Hauck was signing a lease. Although there was no discussion of a mineral deed, Hauck unknowingly signed a deed that conveyed one-half of the minerals on his property to Crawford. Crawford subsequently granted mineral rights to White and Duncan (defendants). Hauck brought an action to quiet title, in order to cancel the mineral deed and other deeds that transferred mineral rights. The trial court cancelled the deeds, finding that the manner in which Hauck’s signature was obtained constituted a forgery. The trial court also found that White and Duncan were bona fide purchasers for value, without making a finding regarding their knowledge of Crawford’s fraud. Crawford, White, and Duncan appealed, claiming that Hauck should not prevail, because he was an intelligent farmer who operated a large farm and was negligent in signing the mineral deed.

Rule of Law

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Holding and Reasoning (Rudolph, J.)

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  • A "yes" or "no" answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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