Luthi v. Evans
Kansas Supreme Court
576 P.2d 1064 (1978)
Owens assigned seven specifically described oil-and-gas leases to Tours, plus a catch-all "Mother Hubbard" clause purporting to convey "all interest" in Coffey County leases "whether or not specifically enumerated above," but the Kufahl lease was never specifically named; when Owens later assigned the Kufahl lease to Burris, he checked the register of deeds and found nothing indicating Tours's prior interest. The trial court found for Burris as an innocent purchaser without notice, but the court of appeals reversed, holding the general Mother Hubbard clause was sufficient notice.
Whether a Mother Hubbard clause in a real-property conveyance puts a subsequent purchaser of an interest in the property on constructive notice of the prior conveyance.