Claugus Family Farm & Forests, L.P. v. Piatt

2025 Ohio 291
CourtOhio Court of Appeals
DecidedJanuary 29, 2025
Docket24 MO 0015
StatusPublished

This text of 2025 Ohio 291 (Claugus Family Farm & Forests, L.P. v. Piatt) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Claugus Family Farm & Forests, L.P. v. Piatt, 2025 Ohio 291 (Ohio Ct. App. 2025).

Opinion

[Cite as Claugus Family Farm & Forests, L.P. v. Piatt, 2025-Ohio-291.]

IN THE COURT OF APPEALS OF OHIO SEVENTH APPELLATE DISTRICT MONROE COUNTY

CLAUGUS FAMILY FARM & FORESTS, L.P.,

Plaintiff-Appellant,

v.

M. F. PIATT ET AL.,

Defendants-Appellees.

OPINION AND JUDGMENT ENTRY Case No. 24 MO 0015

Civil Appeal from the Court of Common Pleas of Monroe County, Ohio Case No. 2023-082

BEFORE: Katelyn Dickey, Carol Ann Robb, Mark A. Hanni, Judges.

JUDGMENT: Affirmed in part. Reversed and Vacated in part.

Atty. Andrew P. Lycans, Critchfield, Critchfield & Johnston, Ltd., for Plaintiff-Appellant and

Atty. Daniel P. Corcoran, Theisen Brock, for Defendants-Appellees.

Dated: January 29, 2025 –2–

DICKEY, J.

{¶1} Plaintiff-Appellant, Claugus Family Farm & Forests, L.P. (surface owner) appeals the judgment entry of the Monroe County Court of Common Pleas sustaining the motion for summary judgment filed on behalf of Defendants-Appellees, John Stephens, Carolyn Stephens, Dean J. Holtsclaw, Mark E. Holtsclaw, James Holtsclaw, Jeff Hamrick, Patricia Jones, Dorothy Hamrick1, Linda Myers, Connie King, Gail Pangborn, and Tina Koslosky (purported royalty interest owners), in this action to quiet title in two fractional royalty interests. In addition to seeking judgment against the foregoing parties, Appellant sought summary judgment against defaulting defendants, Anna Holtsclaw, Wilbur Graydon Holtsclaw, and Alice Boggs Holtsclaw, as well as their unknown heirs, devisees, executors, administrators, relicts, next of kin and assigns, who also had a purported royalty interest as successors of J.T. Craig (collectively “Craig heirs”). The trial court overruled the cross-motion for summary judgment filed on behalf of Appellant in its entirety. {¶2} Appellant’s complaint sought a declaration that two fractional royalty interests, one conveyed to J.T. Craig (“Craig royalty interest”) and the other conveyed to M.F. Piatt (“Piatt royalty interest”) in the same sale of royalty, dated May 14, 1900, have been extinguished by operation of the Marketable Title Act, and to quiet title to the respective royalties interests. Appellant further sought a declaration that it was entitled to royalties that Gulfport Energy Corporation (“Gulfport”) (oil and gas lessee) is holding in suspense pending the outcome of this action. The trial court found two recorded wills containing residuary clauses, which transferred ownership of the Craig royalty and were recorded after the root of title, prevented extinguishment by operation of the MTA, and quieted title to the royalty interest in the Craig heirs. {¶3} In a chart taken directly from the motion for summary judgment filed on behalf of the Craig heirs and copied verbatim into the judgment entry on appeal, the trial court acknowledged M.F. Piatt’s 12.5 percent ownership of the royalty, despite the fact that M.F. Piatt and his unknown heirs, devisees, executors, administrators, relicts, next of kin and assigns (“Piatt heirs”) did not answer or otherwise plead, and default judgment

1 A suggestion of death was filed pursuant to Civil Rule 25(E) on January 17, 2024. Attached to the notice was the certificate of death of Dorothy Hamrick dated December 9, 2024.

Case No. 24 MO 0015 –3–

was entered against them. But for the chart, the trial court does not address the Piatt royalty interest in the summary judgment entry. Further, Appellant’s cross-motion did not seek summary judgment against the heirs of M.F. Piatt. {¶4} Having reviewed the record on appeal, we find the residuary clauses in the two wills at issue in this appeal constitute recorded title transactions, which transferred title to the Craig royalty interest and prevented extinguishment of the pre-root interest by the MTA. We further find the recorded will of a royalty interest owner using a different first name than the transaction creating her interest is a recorded title transaction, where the woman’s identity can be confirmed through public records. Finally, we find the preservation of one fractional royalty interest does not preserve a separate and distinct fractional interest that was transferred to a different person albeit in the same sale of royalty. Accordingly, we affirm the entry of summary judgment in favor of the Craig heirs, but reverse and vacate the entry of summary judgment in favor of the Piatt heirs.

FACTS AND PROCEDURAL HISTORY

{¶5} On May 14, 1900, Isaac and Matilda Agin conveyed “unto J.T. Craig 3/4 and M.F. Piatt the 1/4 part of the one-half part of their royalties of all the oil and gas ...” in the “Sale of Royalty” relating to 40 acres (more or less) recorded at Monroe County Lease Volume 30, Page 140. Appellant is the surface owner of five acres (“Property”) affected by the sale of royalty.

I. The surface chain

{¶6} On September 25, 1907, Matilda and Isaac Agin conveyed 39.94 acres to John G. Agin in a warranty deed recorded in Monroe County, which noted that the property was encumbered by the Craig and Piatt royalty interests. On May 26, 1909, John G. Agin conveyed five of the 39.94 acres to George Keeper via a warranty deed recorded in Monroe County, which noted that the deed was subject to the Craig and Piatt royalty interests. {¶7} A certificate of transfer recorded on September 18, 1934 in Monroe County reads that George Keeper died intestate on January 24, 1934, leaving the five acres (and four acres he had obtained from John and Elisabeth Hickenbottom via a warranty deed

Case No. 24 MO 0015 –4–

recorded in Monroe County on April 3, 1893) to John Keeper (1/3), J.M. Norris (1/9), Eliza Groff (1/9), Ella Willis (1/9), William Farra (1/15), Elmer Farra (1/15), Ida Gadd (1/15) and Mary Whitacre (1/15). The certificate of transfer did not mention either of the royalty interests. {¶8} On December 20, 1934, as the result of a partition action, the sheriff of Monroe County conveyed the five-acre parcel and the four-acre parcel to J.M. Norris via a sheriff’s deed recorded in Monroe County. The sheriff’s deed did not mention either of the royalty interests. {¶9} An affidavit of transfer was recorded on March 26, 1951, in Monroe County reading that J.M. Norris died intestate on July 22, 1948, leaving the five-acre parcel and the four-acre parcel to Ferne Norris (1/3), Stella Copeland (2/9), Beulah Norris (2/9), and Floyd Norris (2/9). The affidavit of transfer did not mention either of the royalty interests. On March 26, 1951, Beulah Norris, Floyd and Celestia Norris, and Stella and Amos Copeland conveyed their interest in the five-acre parcel and the four-acre parcel to Ferne Norris via a quit claim deed recorded in Monroe County. The deed did not mention either of the royalty interests. {¶10} On July 3, 1961, the Auditor of Monroe County conveyed the five-acre parcel and the four-acre parcel in deeds recorded in Monroe County to F.W. Claugus. The deed did not mention either of the royalty interests. On December 1, 1997, Frederick W. Claugus conveyed various parcels, including the five-acre parcel, to Claugus Family Farm, L.P. in a general warranty deed recorded in Monroe County. The deed did not mention either of the royalty interests. {¶11} On December 9, 2021, an Affidavit of Facts Relating to Title was recorded in Monroe County noting that Claugus Family Farm, L.P. had changed its name to Claugus Family Farm & Forests, L.P. effective January 3, 2022.

II. The Piatt royalty interest chain

No estate was filed for M.F. Piatt in Monroe County.

III. The Craig royalty interest chain

Case No. 24 MO 0015 –5–

{¶12} J.T. Craig died testate on March 28, 1943. His will is filed at Monroe County Will Record Volume 17, Page 111.

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2025 Ohio 291, Counsel Stack Legal Research, https://law.counselstack.com/opinion/claugus-family-farm-forests-lp-v-piatt-ohioctapp-2025.