Sheridan v. Cassel

70 So. 3d 89, 11 La.App. 3 Cir. 162, 2011 La. App. LEXIS 726, 2011 WL 2200233
CourtLouisiana Court of Appeal
DecidedJune 8, 2011
Docket11-162
StatusPublished
Cited by3 cases

This text of 70 So. 3d 89 (Sheridan v. Cassel) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sheridan v. Cassel, 70 So. 3d 89, 11 La.App. 3 Cir. 162, 2011 La. App. LEXIS 726, 2011 WL 2200233 (La. Ct. App. 2011).

Opinions

[90]*90GENOVESE, Judge.

| defendant, Tommy Gordon Cassel, appeals a grant of summary judgment in favor of Plaintiff, Carolyn Plummer Sheridan, decreeing Ms. Sheridan to be the owner of all oil, gas, and other minerals under a certain 3.27-acre tract in Sabine Parish, Louisiana. For the following reasons, we affirm the judgment of the trial court.

FACTUAL AND PROCEDURAL HISTORY

On August 13, 2010, Ms. Sheridan filed a petitory action against Mr. Cassel. Ms. Sheridan prayed for judgment declaring her to be “the true and lawful owner of all mineral rights under 3.27 acres lying in the Northwest corner of the East Half of the Southwest Quarter of Section 35, Township 9 North, Range 14 West, Sabine Parish, Louisiana.” According to Ms. Sheridan’s petition, the mineral rights to the 3.27 acres were sold by Mr. Cassel when he conveyed eighty acres to his sister, Gertrude Ray, on April 5, 1969. Ms. Sheridan alleged that Mr. Cassel “failed to reserve any mineral rights”; therefore, “all minerals under the entire [eighty-jacre tract passed to Gerturde Ray.” According to Ms. Sheridan, after Gertrude Ray’s death, Mr. Cassel sold all of his interest in Gertrude Ray’s estate to her and that she owns all oil, gas, and other minerals under the 3.27-acre tract.

Mr. Cassel answered Ms. Sheridan’s petitory action and alleged that “[t]he 3.27 acres of mineral rights at issue were specifically reserved by him when the surface was taken by the Sabine River Authority in June of 1966.” He further contended that:

The judgment of possession in the succession of Gertrude Ray as well as a quitclaim deed executed concurrent with the “conveyance and assignment of an interest of estate” clearly and absolutely showed the reservation and exclusion of the 3.27 acres of mineral rights under the Toledo Bend Reservoir. These interests were excluded because they were not owned by Gertrude Ray but remained in the ownership of [him] pursuant to the previously executed deed.

[2On September 27, 2010, Mr. Cassel filed a Motion for Summary Judgment on the issue of ownership along with a Statement of Undisputed Facts. In his motion, Mr. Cassel asserted that he “retained a permanent, non-prescriptable mineral servitude with respect to the 3.27 acres”; therefore, “there is no genuine issue of material fact with respect to ownership of this mineral servitude as he has never sold or conveyed said mineral servitude to [Ms. Sheridan] or any predecessor and [sic] title of [Ms. Sheridan].” Attached to his Motion for Summary Judgment were the following exhibits: Exhibit 1 — a Warranty Deed, dated December 27, 1965, wherein Mr. Cassel acquired eighty acres from Avis Cassel Thomas; Exhibit 2 — a Cash Sale, dated June 22, 1966, wherein Mr. Cassel transferred the 3.27-acre tract, excluding minerals, to the Sabine River Authority; Exhibit 3 — an Affidavit of Possession, dated June 22, 1966, wherein Mr. Cassel confirmed his possession of the 3.27-acre tract which he conveyed to the Sabine River Authority; Exhibit 4 — a Cash Sale, dated April 5,' 1969, wherein Mr. Cassel transferred eighty acres to Gertrude Ray; Exhibit 5 — a Quitclaim Deed, dated March 18, 1980, wherein Mr. Cassel conveyed to Ms. Sheridan all of his interest in certain real estate belonging to the estate of Gertrude Ray; Exhibit 6 — a Judgment of Possession, dated April 9, 1980; and Exhibit 7 — a Conveyance and Assignment of Interest in [Gertrude Ray’s] Estate dated March 18,1980.

[91]*91Ms. Sheridan also filed a Motion for Summary Judgment on the issue of ownership. In her motion, Ms. Sheridan reiterated her contention that when Mr. Cassel sold the eighty-acre tract to Gertrude Ray on April 5, 1969, Mr. Cassel did not reserve the mineral rights thereto, and, when she bought Mr. Cassel’s interest in Gertrude Ray’s estate in 1980, she acquired all mineral rights to the 8.27-acre tract. laWith the exception of the Affidavit of Possession dated June 22, 1966, Ms. Sheridan attached to her motion the same exhibits offered by Mr. Cassel and, in addition thereto, Exhibit F — a ninety-nine year lease, dated June 24, 1966, wherein Mr. Cassel leased the surface of 1.84 acres of the 3.27-acre tract from the Sabine River Authority.

On December 8, 2010, the trial court denied Mr. Cassel’s motion and issued an order granting Ms. Sheridan’s Motion for Summary Judgment, wherein it held:

Defendant, in the April 5, 1969 cash sale to Gertrude Cassel Ray, conveyed “all rights” to the subject 80 acres without reservation of the mineral rights he possessed from the sale of the subject 3.27 acres to the Sabine River Authority in 1966. Although Defendant possessed no surface property rights to the 3.27 acres, he did possess its mineral rights. Confined to the four-corners of the cash sale contract, Defendant did convey “all rights” to the property as described that includes said 3.27 acres. Thus, Defendant transferred 76.73 surface acres and 80 mineral acres to [Gertrude Ray] that remained with her until her death.
Mr. Cassel appeals.

ASSIGNMENT OF ERROR

On appeal, Mr. Cassel asserts the following assignment of error:

[T]he trial court erred as a matter of law in denying [his] Motion for Summary Judgment [and] granting the Motion for Summary Judgment of [Ms. Sheridan], finding that [he] conveyed a mineral servitude where this incorporeal immovable was not described in the deed, and [he] did not own the surface at the time the deed was executed.

STANDARD OF REVIEW

The Louisiana Supreme Court has set forth the governing jurisprudence relative to a motion for summary judgment and our appellate standard of review as follows:

A motion for summary judgment is a procedural device used when there is no genuine issue of material fact for all or part of the relief prayed for by a litigant. Duncan v. U.S.A.A Ins. Co., [06— 363 (La.11/29/06), 950 So.2d 544, see La. Code Civ.P.] art. 966. A summary judgment is reviewed on appeal de novo, with the appellate court using the same criteria that govern the trial court’s determination |4of whether summary judgment is appropriate; i e. whether there is any genuine issue of material fact, and whether the movant is entitled to judgment as a matter of law. Wright v. Louisiana Power & Light, [06-1181 (La.3/9/07) ], 951 So.2d 1058[ ]; King v. Parish National Bank, [04-0337 (La.10/19/04) ], 885 So.2d 540[ ]; Jones v. Estate of Santiago, [03-1424 (La.4/14/04) ], 870 So.2d 1002[.]

Samaha v. Rau, 07-1726, pp. 3-4 (La.2/26/08), 977 So.2d 880, 882-83 (footnote omitted).1 Louisiana Code of Civil Procedure Article 966 provides:

[92]*92A. (1) The plaintiff or defendant in the principal or any incidental action, with or without supporting affidavits, may move for a summary judgment in his favor for all or part of the relief for which he has prayed. The plaintiffs motion may be made at any time after the answer has been filed. The defendant’s motion may be made at any time.
(2) The summary judgment procedure is designed to secure the just, speedy, and inexpensive determination of every action, except those disallowed by Article 969. The procedure is favored and shall be construed to accomplish these ends.
B.

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Related

Sheridan v. Cassel
70 So. 3d 89 (Louisiana Court of Appeal, 2011)

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Bluebook (online)
70 So. 3d 89, 11 La.App. 3 Cir. 162, 2011 La. App. LEXIS 726, 2011 WL 2200233, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sheridan-v-cassel-lactapp-2011.