Higgins Oil & Fuel Co. v. Delaney

263 F. 931, 1920 U.S. Dist. LEXIS 1294
CourtDistrict Court, W.D. Louisiana
DecidedFebruary 6, 1920
DocketNo. 43
StatusPublished
Cited by1 cases

This text of 263 F. 931 (Higgins Oil & Fuel Co. v. Delaney) is published on Counsel Stack Legal Research, covering District Court, W.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Higgins Oil & Fuel Co. v. Delaney, 263 F. 931, 1920 U.S. Dist. LEXIS 1294 (W.D. La. 1920).

Opinion

JACK, District Judge.

This suit was originally brought at law as an action in jactitation, hut the pleadings were later reformed so as to convert it into one to correct a deed to land, and the case was transferred to the equity docket. The correction sought is the addition to the lands specifically described by government subdivisions, of the E. % of N. E. % of S. E. % °f section 19, containing 16.32 acres.

In 1871, one Langford sold to the minor heirs of Martha Delaney a certain tract of land described by government subdivisions and said to contain 220 acres, more or less. In the recordation of the deed, that portion of the land described as the “S. E. %, of the S. B. % and E. % of N. E. of S. E. % of section 19” was erroneously recorded, “S. _ E. % of S. E. % or E. % of N. E. % of S. E. % of section 19.” At various times thereafter, the defendants J. B. and Anna Delaney bought the interest of the remaining heirs. There was, however, omitted from the deeds from the other heirs the said 16.32 acres which had previously, in the recordation of the deed from Lang-ford, been erroneously preceded by the disjunctive, “or,” instead of the copulative conjunction, “and.”

In 1911, the defendants J. B. and Anna Delaney, having so acquired the interest of the other heirs, sold to Featherston by deeds de[932]*932scribing the land by the same description contained in the deeds from their coheirs, and, consequently, omitting the said E. % of the N. E. % of the S. E. % of section 19. About a month after making the purchase, Featherston made a dation en paiement of said property, as described in his deed, to his wife, and Mrs. Featherston, in 1919, sold to plaintiff Higgins Oil & Fuel Company a one-half interest in the mineral rights in said land so acquired from her husband. A few months thereafter, Featherston sold to Orgain, attorney for Higgins Oil Company, the 16.32 acres herein involved.

This suit was then brought by plaintiffs against J. B. and Anna Delaney and their coheirs, alleging that Featherston had purchased the entire Delaney place; that said E. % of the N. E. % of the S'. E. % of section 19 had been omitted from the deed from J. B. and Anna Delaney to Featherston by error; and praying that such deed be corrected so as to include said E. % of N. E. % of S. E. % °f section 19, and that defendants be enjoined from further claiming or asserting title to said land. Defendants other than J. B. and Anna Delaney, averring sales of their interest in the land to the latter, disclaim any interest in the suit. J. B. and Anna Delaney in answer deny that any error was made, as alleged, in their title to Featherston, and pray that plaintiffs’ demands be rejected.

[1] Neither party is in possession of the land in controversy, and it is contended by the defendants that, consequently, an action in equity to remove a cloud from title cannot be maintained. Pomeroy, in his work on Equitable Remedies (section 731), states:

“When the estate or interest to be protected is equitable, the jurisdiction should he exercised, whether the plaintiff is in or out of possession, for, under these circumstances, legal remedies are not possible. * * * In some of the cases, the rule is so broadly stated as to require a plaintiff seeking to have a cloud removed, under all circumstances, to be in possession, while, on the other hand, it is stated that possession is never essential. Both of these extreme views are open to criticism, and the case should always be considered with reference to the facts actually before the court. Where, however, neither party is in possession, * * * it has been generally admitted that the remedy at law is inadequate, and that equity has jurisdiction to remove or prevent a cloud.”

I think such a suit in equity to remove a cloud from the title may be maintained; furthermore, this suit is primarily one to correct a deed, and, for such purpose, a court of equity clearly has jurisdiction.

[2] Defendant in the trial of the case objected to the admission of any parol testimony to correct or enlarge the deed. The rule that parol testimony is inadmissible to contradict or vary a written instrument is not applicable' in a suit for the reformation of such instrument on allegations of error. Simmons Creek Coal Co. v. Doran, 142 U. S. 417, 12 Sup. Ct. 239, 35 L. Ed. 1063; Ivinson v. Hutton, 98 U. S. 79, 25 L. Ed. 66. See, also, various cases cited in Louisiana Digest Annotated, vol. 3, p. 223.

Negotiations for the purchase of the property were conducted by Featherston with J. B. Delaney. The testimony of the former is that he proposed to Delaney to purchase the Delaney home place, and offered a price of $1,000, which Delaney accepted; that the iatter [933]*933stated at the time that the place contained 220 acres; that he (Featherston) thereafter met Delaney and his sister, Anna Delaney, at the office of Mr. Fortson, recorder; and that, on their statement that Featherston had bought the Delaney place, and their request to draw the deed, Fortson did so, getting the description from the deeds to J. B. and Anna Delaney from their coheirs, in which deeds, as before stated, was not included the land in controversy. This is likewise, in effect, the testimony of Mr. Fortson, and the defendants. Plaintiffs’ contention is based on the claim that he intended to buy, and J. B. and Anna Delaney intended to sell, all of the home place, and that, the land in controversy having been omitted in error, the deed should now be corrected so as to include it.

Delaney testifies that he purposely omitted the land because he was advised to do so by Mr. Ferguson, now deceased, former clerk of court, who stated that there was some question as to the title. Anna Delaney in her testimony made no allusion to such advice from Ferguson, and swears frankly that she did not think she was reserving any of the land from the deed. Delaney subsequently told other parties that he had sold all of his land. He does not claim to have mentioned Ferguson’s advice to Featherston„at the time of the sale, and his belated statement as to such neither harmonizes with the testimony of other witnesses nor his own, and I cannot accept it as true. I think the evidence conclusively shows that Featherston did, in fact, intend to buy, and J. B. and Anna Delaney did intend to sell, all of the land embraced in the Delaney place, and that the land in controversy was omitted because neither they nor Featherston knew that they owned it. Featherston did not discover that the Delaneys did own the land in question until eight years after his purchase, and would not then have discovered it, but for the fact that the land, had become very valuable, worth in excess of $500 an acre, by reason of the oil development on neighboring lands. The alleged error was finally discovered, not by Featherston, but by the Higgins Oil & Fuel Company, in whose deed to one-half mineral rights was not included the land in controversy, and who had no interest whatever therein.

Upon such discovery, Orgain, realizing the fact that the land in question could not be claimed under the deed to his company, as it was neither included in that deed nor in the deed from Featherston to his wife, although the description in such deeds was identical with the description in the deed from the Delaneys, to Featherston, took, in his own name, a deed direct from Featherston to the land in question.

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Related

Higgins Oil & Fuel Co. v. Delaney
271 F. 1021 (Fifth Circuit, 1921)

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Bluebook (online)
263 F. 931, 1920 U.S. Dist. LEXIS 1294, Counsel Stack Legal Research, https://law.counselstack.com/opinion/higgins-oil-fuel-co-v-delaney-lawd-1920.