Oklahoma Ex Rel. Commissioners of Land Office v. Butler

Butler (plaintiff) bought land originally sold by the State of Oklahoma (defendant), which had reserved rights to "oil, gas and other minerals and mineral rights"; Butler sued to quiet title to the coal on the land, and the state Land Office Commissioners (defendants) counterclaimed to quiet title to the coal in the state's favor, arguing the reservation clause was ambiguous and required extrinsic evidence to interpret. The trial court granted Butler summary judgment, and the Commissioners appealed.