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Oklahoma Ex Rel. Commissioners of Land Office v. Butler

Supreme Court of Oklahoma
753 P.2d 1334 (Okla. 1987)


Facts

Claude Butler (plaintiff) bought parcels of land that the seller initially acquired from the State of Oklahoma (defendant). In the initial sales, the state reserved for itself a portion of the rights to “oil, gas and other minerals and mineral rights.” Butler brought suit against the state to quiet title in the right to coal on the land. The Oklahoma Commissioners of Land Office (Commissioners) (defendants) counterclaimed to quiet title in the state’s interest in the coal. Butler argued that the definition of “other minerals” did not include coal. The Commissioners argued that it should be permitted to introduce extrinsic evidence on the issue. The trial court granted Butler’s motion for summary judgment. The Commissioners appealed, arguing that the phrase “oil, gas and other minerals” is ambiguous and requires parol evidence to effectuate intent of the parties to the sale.

Rule of Law

The rule of law is the black letter law upon which the court rested its decision.

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Issue

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Holding and Reasoning (Simms, 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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