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James Clark v. Amoco Production Company
Citations: 908 F.2d 29; 1990 WL 105817Docket: 89-6075
Court: Court of Appeals for the Fifth Circuit; September 12, 1990; Federal Appellate Court
Plaintiffs James Clark and Dan Profitt, as administrators of James R. Meadors's estate, filed a diversity lawsuit against four oil companies, alleging unauthorized extraction of oil and gas from lands in which Meadors held a one-eighth interest. The district court granted summary judgment for the defendants, determining that the relevant deed only conveyed rights to four specific tracts of land, none of which the companies had ever owned. The plaintiffs' claim was rooted in a 1911 deed that they interpreted as granting rights to all properties inherited by the McFadden family, including valuable oil-producing land in Jefferson County, Texas. The plaintiffs had previously attempted to establish Meadors's interest through a Texas state court suit, which was dismissed and not appealed. After being appointed administrators of the estate in 1983, they brought the current suit in federal court, seeking to prove Meadors's interest and obtain an accounting of royalties, estimating potential damages at twenty billion dollars. The defendants successfully moved to dismiss the case, citing the doctrines of laches and presumed lost deed, while the district court did not rule on the res judicata argument. The appellate court affirmed the district court's decision, finding no error in its judgment. In Clark I, the court reversed and remanded the case, determining that the complaint did not establish the affirmative defenses of laches or presumed lost deed, nor was the claim barred by res judicata due to the lack of identical parties in the prior lawsuit. The court highlighted the possibility of resolving the case without a full trial through available expeditious procedures. On remand, the district court granted summary judgment for the oil companies, finding that the 1911 deed clearly conveyed interest in only four specific parcels of land and that the oil companies had no ownership or production rights related to those properties. The plaintiffs argued that the 1911 deed was ambiguous regarding its coverage, asserting the necessity of extrinsic evidence to clarify this. The oil companies countered that the deed was unambiguous and the court appropriately excluded extrinsic evidence that would create ambiguity rather than resolve it. The court agreed with the oil companies, noting that the deed explicitly stated it conveyed four tracts, and any claim of ambiguity arose only when extrinsic evidence was introduced to contradict the deed's clear terms. Texas law prohibits the admission of parol evidence that creates ambiguity or alters the meaning of a deed's language. The court referenced precedents illustrating that extrinsic evidence cannot be used to contradict the clear terms of a deed, thereby affirming the unambiguous nature of the 1911 deed. The court determined that the Meadors estate is entitled to only a one-eighth interest in four specific tracts of land as outlined in a 1911 deed. The evidence showed that the oil companies involved never owned interests in these parcels or extracted oil or gas from them, leading to the affirmation of the district court's summary judgment in favor of the companies. The lands in question include those associated with the historically significant Spindletop Oil Field, which has been a major oil production site since 1901. The deed specifically grants James Meaders a one-eighth interest in the tracts inherited by the McFadden family from William McFadden. However, the plaintiffs failed to demonstrate a complete chain of title for three of the four tracts, as indicated by estate records. The court also referenced the presumed lost deed doctrine, which requires proof of an open claim and acquiescence by the apparent owner. Additionally, a prior summary judgment in favor of Texaco Inc. was not contested on appeal, leaving only the other three oil companies’ liabilities in question. The court did not need to address whether the plaintiffs established a complete chain of title for the four parcels.