Thompson v. Estate of Coffield

The estate of H. H. Coffield (defendant) sold 4,000 acres to Thompson (plaintiff) via a deed reserving a one-half mineral royalty interest to the estate, providing that mineral interests under recorded or probate-confirmed leases would not vest in Thompson until those leases expired; several coal leases the estate had executed were confirmed by probate court but never recorded with the county clerk. Thompson sued for $40,000 in royalties, arguing the unrecorded leases meant half the mineral interests transferred to him immediately rather than at lease expiration, while the estate counterclaimed for reformation, arguing Thompson knew of the leases at the sale and both parties understood the estate would retain all royalties until the leases expired. The trial court refused to admit any evidence beyond the deed itself and ruled for Thompson; the court of appeals affirmed, and the Oklahoma Supreme Court granted certiorari.