Simmons Group, LTD v. Caine O’Rear, Jr. Family Trust

This case began as an interpleader action filed by El Paso E&P Production, L.P. ("El Paso"), to determine who owned the mineral interest in a piece of property located in Walker County ("the Landon parcel"), on which El Paso operated a methane well. The competing claimants for the mineral interest were Simmons Group, LTD, and the Caine O'Rear, Jr. Family Trust, Mary Lou Foy, Susan Foy Spratling, Paula Robertson Rose, Stacy Baker Carson, and Warren Dane Baker (referred to collectively as "O'Rear"). Simmons Group claimed ownership by an unbroken chain of conveyances starting with an 1883 quitclaim deed from Elizer Taylor to Musgrove Bros. purporting to convey the mineral interest ("the 1883 deed"). O'Rear claimed ownership by a separate chain of conveyances originating in the adverse possession of the Landon parcel by J.K.P. Chilton and allegedly ripening into ownership sometime before 1921. O'Rear argued that the 1883 deed did not validly convey the mineral interest and that the mineral interest was not severed from the surface estate until after Chilton adversely possessed the Landon parcel. O'Rear did not dispute Simmons Group's chain of title subsequent to the 1883 deed. Thus, it was undisputed that, if the 1883 deed validly conveyed the mineral interest to Musgrove Bros., Simmons Group was the rightful owner. Ownership of the mineral interest was the dispositive issue in this case. The circuit court determined that Chilton had adversely possessed the Landon parcel with the mineral interest still attached and that O'Rear therefore owned the mineral interest. The Supreme Court reversed, finding the first conveyance of the mineral interest recorded after the total destruction of the Walker County land records was the 1883 deed. As such, the 1883 deed was the presumed beginning point of the chain of title, and O'Rear offered no evidence sufficient to rebut this presumption. Therefore, the Court held that title to the mineral interest in the Landon parcel vests in Simmons Group. View "Simmons Group, LTD v. Caine O'Rear, Jr. Family Trust" on Justia Law