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Platt v. Held

Citation: 2018 MT 43Docket: 17-0116

Court: Montana Supreme Court; March 13, 2018; Montana; State Supreme Court

Original Court Document: View Document

Narrative Opinion Summary

In the case before the Montana Supreme Court, the primary issues revolved around the statute of limitations for mutual mistake claims and the use of extrinsic evidence in contract reformation. The dispute involved parties who purchased a large ranch and later divided it into parcels with specific usage rights. Conflicting interpretations of the Recorded Agreement led to litigation, with plaintiffs arguing for its reformation based on mutual mistake. The District Court ruled that the statute of limitations did not bar the claims, as the mistake was not discoverable until litigation ensued. The court accepted extrinsic evidence to reform the contract, aligning it with the parties' original intent of non-exclusive, non-transferable licenses. The Supreme Court upheld this decision, affirming that mutual mistake allowed for contract revision and supporting the use of extrinsic evidence to reflect true intentions. The court noted that while fraud could also justify reformation, it was unnecessary to address given the mutual mistake basis. Ultimately, the ruling ensured that usage rights were equitable and terminated upon sale or death, clarifying the parties' obligations and rights under the revised agreement.

Legal Issues Addressed

Mutual Mistake as a Basis for Contract Reformation

Application: The court reformed the Recorded Agreement by removing the word 'exclusive' from Held's grazing rights to align with the parties' mutual intent.

Reasoning: The District Court concluded that due to the mistake, the signed document did not accurately reflect the mutual intent regarding usage rights.

Non-Exclusive, Non-Transferable Licenses

Application: The court interpreted the parties' intent to create licenses that would terminate upon the sale of parcels or death of the parties, ensuring no burden on future land transactions.

Reasoning: The District Court determined that the parties intended to create non-exclusive, non-transferable licenses that could be revoked upon death or sale of the respective parcels.

Statute of Limitations in Mutual Mistake Claims

Application: The court determined that the statute of limitations did not begin until after the lawsuit was filed, allowing Platt's and Welu's claims to proceed.

Reasoning: The court found that the relevant statutes of limitation did not begin until after the lawsuit was filed, thus deeming Platt's and Welu's claims timely.

Use of Extrinsic Evidence in Contract Reformation

Application: The court allowed the use of extrinsic evidence to determine the parties' true intentions and reform the contract due to mutual mistake.

Reasoning: The District Court concluded that due to the mistake, the signed document did not accurately reflect the mutual intent regarding usage rights. This conclusion was supported by substantial evidence, validating the need for extrinsic evidence to reform the contract.