Atlantic Richfield Co. v. State Ex Rel. Wildlife Conservation Commission

1983 OK 14, 659 P.2d 930, 1983 Okla. LEXIS 149
CourtSupreme Court of Oklahoma
DecidedFebruary 8, 1983
Docket54234, 54245
StatusPublished
Cited by29 cases

This text of 1983 OK 14 (Atlantic Richfield Co. v. State Ex Rel. Wildlife Conservation Commission) is published on Counsel Stack Legal Research, covering Supreme Court of Oklahoma primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Atlantic Richfield Co. v. State Ex Rel. Wildlife Conservation Commission, 1983 OK 14, 659 P.2d 930, 1983 Okla. LEXIS 149 (Okla. 1983).

Opinions

OP ALA, Justice:

The questions posed on certiorari are: [1] Does the purchaser at a judicial sale acquire any interest in the subject property prior to confirmation? and if so, [2] Is a quit claim deed, executed by the purchaser before the sale is confirmed, effective, after confirmation, to invest the transferee with legal title? and [3] When the purchaser at partition sale was the common source of title for all parties in a quiet-title suit, was an alleged collusion between him and the land’s court appraiser (his immediate transferee who was then under legal disability, pursuant to 12 O.S. 1981 § 769,1 to purchase the property directly or indirectly) a defect material in determining which of the purchaser’s successors-in-interest held superior title?2

We hold that: (a) upon payment of the purchase price, the buyer at judicial sale acquires equitable title to the subject property, which may be transferred by quitclaim deed prior to judicial confirmation of the sale; (b) upon the court’s confirmation, equitable title so transferred will ripen into full legal title; and (c) as between the parties-opponent herein, whose titles- — derived through a common source — stand affected by the same infirmity, the one holding the older title from that source must prevail.

The State of Oklahoma, ex rel. the Wildlife Conservation Commission [State], sought to quiet its title in certain Latimer County land. The State derived its title by a 1935 warranty deed from J.W. Martin [Martin] who acquired title by a 1930 quit [933]*933claim deed from Carlton Weaver [Weaver]. Martin was one of three appraisers appointed by the court to valúate the property prior to its judicial sale in a partition case. Weaver purchased the property at the judicial sale and then sold it to Martin [appraiser] some two weeks later. The conveyance to the appraiser took place before judicial confirmation of the sale to Weaver. The appellants (defendants) are oil companies who, in conjunction with other defendants below, claim ownership of a fractional mineral interest in the subject property through mineral conveyances executed by Weaver in 1981 to their common predecessor in title, R.W. McKissick, after the quit claim deed to Martin had been placed of record.

The trial court found (1) that equitable title passed to Weaver at the judicial sale and thereafter to the appraiser by quit claim deed from Weaver; and following issuance of sheriff’s deed, it ripened into legal title; (2) that the deed from Weaver to McKissick was executed after the quit claim deed to the appraiser, as well as after confirmation of sale and issuance of sheriff’s deed — all of which prior transfers were recorded and constituted notice to McKis-sick and his successors and (3) the later purchase by the appraiser was not of itself indicative of fraud or collusion between Weaver and the appraiser.

Affirming the trial court’s decree, the Court of Appeals held that (1) a quit claim deed may effectively transfer to another equitable title obtained by a purchaser at a judicial sale prior to judicial confirmation; and that following such confirmation, the equitable title so transferred would ripen into full legal title; and (2) that Martin, as the property’s appraiser, held title that was merely voidable and thus not subject to collateral attack in the instant suit.

We granted certiorari on the petition of the appellants (oil companies) and now reaffirm the trial court’s decree.

I.

The oil companies question the sufficiency of Weaver’s title at the time he executed the quit claim deed to the appraiser, i.e. before confirmation of sale and execution of the sheriff’s deed. The law is well settled that a successful bidder at the sheriff’s sale does acquire equitable title and certain other inchoate rights of ownership in the property, subject to confirmation and payment of the purchase price.3 Such equitable title — obtained upon payment of the purchase price to the sheriff — can effectively be quit claimed to another prior to confirmation. When, following confirmation of sale and the delivery of the sheriff’s deed, legal title becomes vested in the purchaser, it will inure to the benefit of his prior grantee.4

II.

Oil companies contend that an appraiser in a partition action cannot, either directly or indirectly, purchase the appraised lands at a subsequent sheriff’s sale and that title to property acquired by an appraiser is void ab initio because the statutory disability which attaches to him is personal and perpetual.

The predecessor of § 769 (§ 5171, 1910 Revised Laws) — along with other statutes governing judicial sales- — was taken from the laws of Kansas. In 1930, when the sale in question occurred, § 5171 provided that “... [n]o sheriff or other officer making the sale of property, either personal or real, nor any appraiser of such property, shall, either directly or indirectly, purchase the same; and every purchase so made shall be considered fraudulent and void.”5 [Emphasis added]. This language appears in substantially the same form in the successor [934]*934statute (§ 769).6 When the law was adopted in Oklahoma, Kansas had judicially construed her statute as an absolute prohibition against the purchase of property at a judicial sale by an officer conducting such sale.7

At the time Oklahoma adopted the Kansas statute, Kansas had not yet judicially tested its counterpart provisions with respect to indirect sales to an appraiser. The point pressed on us here — that an appraiser is personally forever barred from acquiring the affected property — remains unsettled in Oklahoma. Some jurisdictions have addressed this question and determined that under certain circumstances a person under the appraiser’s disability may later acquire the appraised property. In those cases, the purchase was neither shown to have occurred at, nor to have been connected with, the judicial sale in which the official was involved.8 Other jurisdictions have held that the validity of a post-sale purchase by an official — in light of a statutory prohibition like or similar to that in § 769 — depends on the official’s motives.9

We need not intimate here any view on (1) whether the title acquired by Martin, the appraiser, was void or merely voidable or (2) whether the § 769 disability could be overcome by an evidentiary showing that the “indirect” acquisition of property by an official under disability from the direct purchaser at a judicial sale was neither “prearranged” nor “collusive” but one that originated from a separate transaction made under circumstances disconnected from the prior judicial sale. The trial court must be affirmed because, for the reasons to be stated, its judgment reaches a legally correct result.10

While, ordinarily, in a quiet title suit the plaintiff bears the burden of establish[935]*935ing the superiority of his own title, rather than the weakness of his adversary’s,11 when both parties derive title from a common source in their respective chains of title, the plaintiff need only establish a valid interest in title derived from the common source,

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Cite This Page — Counsel Stack

Bluebook (online)
1983 OK 14, 659 P.2d 930, 1983 Okla. LEXIS 149, Counsel Stack Legal Research, https://law.counselstack.com/opinion/atlantic-richfield-co-v-state-ex-rel-wildlife-conservation-commission-okla-1983.