Buckhorn Resources, LLC v. Combs Heirs, LLC

CourtCourt of Appeals of Kentucky
DecidedOctober 29, 2020
Docket2018 CA 001073
StatusUnknown

This text of Buckhorn Resources, LLC v. Combs Heirs, LLC (Buckhorn Resources, LLC v. Combs Heirs, LLC) is published on Counsel Stack Legal Research, covering Court of Appeals of Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Buckhorn Resources, LLC v. Combs Heirs, LLC, (Ky. Ct. App. 2020).

Opinion

RENDERED: OCTOBER 30, 2020; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals

NO. 2018-CA-1073-MR

BUCKHORN RESOURCES, LLC APPELLANT

APPEAL FROM LESLIE CIRCUIT COURT v. HONORABLE OSCAR GAYLE HOUSE, JUDGE ACTION NO. 09-CI-00256

COMBS HEIRS, LLC; SAMUEL L. COMBS; LAURA COMBS; B.C. NOLAN TRUST BY VIRGINIA NOLAN CRAFT; CATHERINE B. NOLAN BY VIRGINIA NOLAN CRAFT; FRANK PETERS; PATRICIA S. PETERS; AND ICG HAZARD, LLC APPELLEES

OPINION AFFIRMING

** ** ** ** **

BEFORE: CALDWELL, DIXON, AND L. THOMPSON, JUDGES.

DIXON, JUDGE: Buckhorn Resources, LLC, (“Buckhorn”) appeals from the

judgment declaring its property deeds void as champertous and awarding royalties

for coal mining by ICG Hazard, LLC, (“ICG”) on the property to Combs Heirs, LLC; Samuel L. Combs; Laura Combs; B.C. Nolan Trust by Virginia Nolan Craft;

Catherine B. Nolan by Virginia Nolan Craft; Frank Peters; and Patricia S. Peters

(“Combs Heirs”) entered on June 5, 2018,1 by the Leslie Circuit Court. Following

review of the record, briefs, and law, we affirm.

FACTS AND PROCEDURAL BACKGROUND

On October 21, 2009, the Combs Heirs sued ICG for unpaid royalties

for coal mining on their property. The heirs attached an unsigned memorandum of

lease agreement, which was also undated beyond indicating the year was 2000,2 to

their complaint. This memorandum identified the property as:

located on the waters of Coal Branch and Long Fork of Langdon Branch, tributaries of the Middle Fork of the Kentucky River, in Leslie County, Kentucky, said property (i) being more particularly described on Exhibit A attached hereto, (ii) being shown on the map attached as Exhibit B to the Agreement (as defined below), and (iii) being hereinafter referred to as the “Leased Premises[.]”

However, neither Exhibit A nor B was made a part of the record.

1 The circuit clerk mistakenly indicated that this order was entered on May 5, 2018, although it was signed and dated by the trial court on June 5, 2018. Buckhorn subsequently moved the trial court to correct the record on appeal (on July 3, 2019) to reflect the June 5, 2018, date of this order, which was granted (on August 22, 2019). 2 This lease was between the Combs Heirs and Leslie Resources. The parties allege the lease was entered on February 9, 2000. ICG replaced Leslie Resources as the lessee on September 30, 2005.

-2- On December 1, 2009, ICG moved the trial court for leave to join

Buckhorn as a party to this action, asserting that ICG had competing coal mining

leases with the Combs Heirs, as well as Buckhorn, for what it referred to as the

“Dr. Combs Property.” Along with this motion, ICG tendered a counterclaim

against the Combs Heirs and Buckhorn seeking a declaratory judgment to

determine the proper recipient of the disputed coal mining royalties. The following

day, the court entered two agreed orders: the first required that ICG deposit the

disputed royalties with the court pending resolution of this matter, and the second

granted ICG’s motion for leave to join Buckhorn as a counterclaim defendant. The

Combs Heirs answered ICG’s counterclaim, alleging Buckhorn’s claim “is barred

by champerty and a complete failure of title, if any[.]” Buckhorn counterclaimed

against ICG for its failure to pay royalties pursuant to the coal mining lease dated

September 1, 2009.

Nearly seven years later, the Combs Heirs moved the trial court for

summary judgment. The Combs Heirs asserted that this case involved

approximately 440 acres of land on the Coal Branch of the Middle Fork of the

Kentucky River in Leslie County, Kentucky, of which they claimed their family

had possession for over 100 years. They further asserted that the principles of res

judicata and collateral estoppel entitled them to judgment as a matter of law

-3- because Buckhorn’s 2005 deeds had been declared void for champerty in two other

circuit court cases.3

On June 5, 2018, the court entered its judgment finding the

prospecting, core-drilling, and mining constituted sufficient evidence of possession

to void Buckhorn’s deeds as champertous under KRS4 372.080. The court also

awarded the unpaid coal mining royalties to the Combs Heirs. Buckhorn moved

the court to alter, amend, or vacate its order pursuant to CR5 59.01(f). While this

motion was pending, Buckhorn filed its notice of appeal.6 The court subsequently

denied Buckhorn’s motion to alter, amend, or vacate.

NONCOMPLIANCE WITH RULES OF APPELLATE PROCEDURE

Another panel of our Court has recently addressed the growing

problem of noncompliance with the rules of appellate practice.

This Court is weary of the need to render opinions such as this one, necessitated as they are by the failure of appellate advocates to follow rules of appellate advocacy. In just the last two years, at least one hundred and one 3 By order of the Perry Circuit Court, Action No. 08-CI-00073, entered November 27, 2012, the court found Leslie Resources was in actual possession of at least portions of the area in dispute; therefore, it found the portion of the deed relating to that property in Perry County void for champerty. By order of the Leslie Circuit Court, Action No. 08-CI-00023, entered August 11, 2014, the court found “the deed” from East Kentucky Land Corporation to Buckhorn void for champerty. 4 Kentucky Revised Statutes. 5 Kentucky Rules of Civil Procedure. 6 The Supreme Court of Kentucky has found the premature notice of appeal related forward, citing CR 73.02(1)(e)(i). Johnson v. Smith, 885 S.W.2d 944, 950 (Ky. 1994).

-4- (101) Kentucky appellate opinions were rendered in which an attorney’s carelessness made appellate rule violations an issue in his or her client’s case. The prodigious number of attorneys appearing in Kentucky’s appellate courts lacking the skill, will, or interest in following procedural rules is growing. In 2005, only two (2) Kentucky opinions addressed appellate rules violations. In 2010, the number jumped to eleven (11). In 2015, the number rose slightly to fourteen (14). The average for the last two years is more than three times that. If this is not a crisis yet, it soon will be if trends do not reverse.

We will not reiterate all that has been said too many times before on this subject. If a lawyer is curious about the importance of these procedural rules or the practical reasons for following them, we recommend reading these opinions in chronological order: Commonwealth v. Roth, 567 S.W.3d 591 (Ky. 2019); Koester v. Koester, 569 S.W.3d 412 (Ky. App. 2019); Hallis v. Hallis, 328 S.W.3d 694 (Ky. App. 2010); Elwell v. Stone, 799 S.W.2d 46 (Ky. App. 1990).

. . . Some rule violations are alone sufficient to justify applying a manifest injustice standard of review or, worse, striking the brief. CR 76.12(8); see also Roth, 567 S.W.3d at 593; Mullins v. Ashland Oil, Inc., 389 S.W.3d 149, 154 (Ky. App. 2012). Other violations are less profound; however, “there is an important purpose behind each of these rules.” Hallis, 328 S.W.3d at 696 (referring by footnote to the purpose underlying some of the more mundane rules).

Clark v. Workman, 604 S.W.3d 616, 616-18 (Ky. App. 2020) (footnotes omitted).

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Buckhorn Resources, LLC v. Combs Heirs, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/buckhorn-resources-llc-v-combs-heirs-llc-kyctapp-2020.