Martin v. Thalman

620 S.W.2d 151, 1981 Tex. App. LEXIS 3437
CourtCourt of Appeals of Texas
DecidedMarch 25, 1981
DocketNo. 16452
StatusPublished
Cited by4 cases

This text of 620 S.W.2d 151 (Martin v. Thalman) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Martin v. Thalman, 620 S.W.2d 151, 1981 Tex. App. LEXIS 3437 (Tex. Ct. App. 1981).

Opinions

OPINION

KLINGEMAN, Justice.

This is the third appeal in this case. The underlying facts of the case are basically set forth in the opinions in the two previous appeals, Porter v. Thalman, 516 S.W.2d 755 (Tex.Civ.App.—San Antonio 1974, writ ref’d n. r. e.), and Martin v. Thalman, 568 S.W.2d 460 (Tex.Civ.App.—Beaumont 1978, no writ). Essentially, the suit concerns the exchange of deeds between Mrs. Porter and the Thalmans, made pursuant to a settlement agreement entered into between them in September, 1969, in an injunction suit brought by Mrs. Porter. The settlement agreement provided that the parties would exchange two forty-acre tracts of land “conditioned, however, that the mineral rights which the parties may convey to each other in this exchange of forty-acre blocks is equal, not referring to value but equal in interest, in realty interest, that is.” Deeds were prepared and subsequently executed pursuant to this agreement; however, it was eventually discovered that the deeds did not convey equal mineral interests.

On this appeal, appellants, who will generally be referred to herein as the “Porter heirs,” appeal from a judgment of the trial court reforming the deed of conveyance of Mrs. Porter to the Thalmans and deleting from the Porter deed a reservation of one-half of the mineral interest for a term of 25 years reserved in favor of Mrs. Porter. Trial was to a jury with a number of special issues submitted.1 On the basis of such jury findings, the trial court entered judgment reforming the Porter deed so that it would convey an undivided one-half interest in the minerals to the Thalmans; ordering that the Thalmans recover from Porter and Sun Oil $14,363.74 because Sun Oil had actual and lis pendens notice of the Thalmans’ claim; and holding that all claims against the Stigalls, a subsequent purchaser of the tract deeded to Mrs. Porter by the Thal-mans, were barred by the statute of limitations. The trial court in its judgment found that both parties intended to convey one-half interest in the minerals and that all equities were in favor of the Thalmans.

As hereinbefore mentioned, this is the third appeal of this case. In the first trial, judgment was entered after a jury trial reforming the deed of conveyance from Mrs. Porter to the Thalmans so as to delete [153]*153a mineral reservation by Mrs. Porter of one-half interest in the mineral rights for a term of twenty-five years. On appeal, this court held that the trial court erred in overruling Mrs. Porter’s objections to the submission of the issue of mutual mistake in the absence of timely pleadings on that issue, and that since the judgment was based on a jury finding of mutual mistake such error required a reversal of the judgment and a remand of the case. See Porter v. Thalman, supra. On remand, a summary judgment for specific performance was entered against the Porter heirs ordering the Porter heirs to convey to the Thalmans the one-half mineral interest retained by Mrs. Porter. This case was again appealed and the Beaumont Court of Civil Appeals reversed and remanded holding that there was insufficient legal description of the tracts to be exchanged and that under the circumstances the ends of justice would best be resolved by remanding rather than rendering judgment. See Martin v. Thal-man, supra. These two opinions contain a detailed statement of the underlying facts of the case and we will not repeat them in detail. Basically, it is sufficient to state that in 1969 Mrs. Porter and C. L. Thalman entered into a settlement agreement in an injunction suit brought by Mrs. Porter. They agreed to exchange two forty-acre tracts of land and to exchange equal mineral interests in the tracts, if any. Two deeds were exchanged and the suit was dismissed with prejudice against Mrs. Porter. When oil was discovered on the tract conveyed to Thalman, he discovered that Mrs. Porter had retained a one-half mineral interest and failed to convey any mineral interest to him; whereas, he and his wife had conveyed a one-half mineral interest to Mrs. Porter.

The problem here arises in part because both 40-acre tracts of land held outstanding mineral interest reservations of one-half of the mineral interests for a term of years, and the deed of exchange given by Mrs. Porter to the Thalmans specifically recited that such tract was subject to an outstanding mineral reservation of an undivided one-half interest for a term of years. Addi-. tionally, Mrs. Porter reserved another one-half interest in the minerals for a term of years in favor of herself. On the other hand, the deed of conveyance of the 40-acre tract from the Thalmans to Mrs. Porter recited that such tract was subject to an existing outstanding one-half mineral interest in a third party, but made no additional mineral reservation therein. Sun Oil Company had an oil, gas and mineral lease on the property conveyed by Mrs. Porter to the Thalmans. The Thalmans filed a lis pen-dens notice in June, 1971, shortly after this suit was brought; however, Sun Oil Company continued to make payments of royalties to Mrs. Porter through 1974 on the lands conveyed by Mrs. Porter to the Thalmans. The tract of land that was conveyed by the Thalmans to Mrs. Porter was subsequently conveyed to the Stigalls.

The Porter heirs assert eight points of error. We will first discuss their first three points of error, which are as follows: The trial court erred in granting judgment reforming the Porter to Thalman deed because (1) plaintiffs (Thalmans) failed to establish the true agreement of the parties regarding the percentage of minerals to be conveyed; (2) there is no evidence that the parties were mutually mistaken concerning Porter’s reservation of a 25-year term mineral interest; and (3) any jury finding on Special Issue No. 3 indicating that the parties were mutually mistaken concerning Porter’s reservation of a 25-year term mineral interest is not supported by sufficient evidence.

In support of these points of error the Porter heirs basically contend (1) although the judgment of reformation is based on mutual mistake, there was no mistake on the part of Mrs. Porter and she conveyed just what she wanted to convey; (2) the Thalmans had the burden of proving the true agreement between the parties which they wholly failed to do; (3) the Thalmans’ judgment must fail because they failed to submit and secure jury findings on material controlling issues necessary to support the judgment of reformation; and (4) the Thal-mans failed to obtain a jury finding that [154]*154the parties intended to convey an undivided one-half interest in the minerals and there is no jury finding that there was any agreement to convey an undivided one-half interest in the minerals.

The equitable reformation of a written contract is based upon the premise that a contract was actually made, but the written memorandum thereof, because of a mutual mistake, does not truly reflect the actual agreement of the parties. Reformation is a proper remedy when the parties have reached a definitive and explicit agreement, understood in the same sense by both, but, by their mutual or common mistake, the written contract fails to express the agreement. Champlin Oil & Refining Co. v. Chastain, 403 S.W.2d 376 (Tex.1965); First National Indemnity Co. v. Conway,

Related

Huttleston v. Beacon National Insurance Co.
822 S.W.2d 741 (Court of Appeals of Texas, 1992)
Living Christ Church, Inc. v. Jones
734 S.W.2d 417 (Court of Appeals of Texas, 1987)
Thalman v. Martin
635 S.W.2d 411 (Texas Supreme Court, 1982)

Cite This Page — Counsel Stack

Bluebook (online)
620 S.W.2d 151, 1981 Tex. App. LEXIS 3437, Counsel Stack Legal Research, https://law.counselstack.com/opinion/martin-v-thalman-texapp-1981.