Steadman v. Uptown Motors, Inc.

Citations: 842 So. 2d 684; 157 Oil & Gas Rep. 708; 2002 Ala. Civ. App. LEXIS 193; 2002 WL 399217Docket: 2001168

Court: Court of Civil Appeals of Alabama; March 14, 2002; Alabama; State Appellate Court

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On December 8, 2000, Uptown Motors, Inc. initiated a lawsuit against Francis LaJoy Steadman, seeking a judicial division of jointly owned real property. Following an ore tenus hearing, the trial court ruled on June 29, 2001, to sell the property. Steadman appealed, and the case was subsequently transferred to this court.

According to Alabama Code § 35-6-20, a joint owner can petition for partition or sale of real property. The trial court has original jurisdiction in matters concerning the division of property among joint owners. Before authorizing a sale, it must be established that the property cannot be equitably divided. The burden of proof lies with the party seeking the sale, as established in several Alabama cases.

In this case, the disputed property comprises 80 acres in Walker County, which has been in Steadman's family for approximately 60 years. After the death of Steadman’s mother, he and his two sisters acquired the interests of other heirs, resulting in Steadman, along with his sisters, owning undivided one-third interests. One of the sisters later transferred part of her interest to her daughter. Uptown Motors, engaged in coal mining, owns adjacent land and has sought to mine the disputed property, acquiring interests from Steadman's sisters but not from Steadman himself.

Uptown Motors filed for division, implying that the property could not be equitably divided among the owners. In contrast, Steadman argued that the property could be divided so that he would retain his one-third interest, preferring a division that would give him the northern section of the property.

Uptown Motors presented a map showing areas with preliminary permits for coal mining, indicating plans to utilize most of the disputed property for this purpose. Steadman argued that partitioning the property to reflect his interest would necessarily include land Uptown Motors intended to mine. Charles Justice, president of Uptown Motors, described the property as unimproved, consisting of hills and hollows, previously cleared for timber, and currently overgrown. He stated it had no economic value aside from potential coal mining and detailed plans for mining operations, including constructing a sediment pond. Justice expressed that the property could not be divided without hindering mining efficiency and suggested auctioning the property instead.

Professional mineral engineer Steven R. Ingle supported Uptown Motors' mining plans but noted he couldn't assess the property for coal due to ownership disputes. He indicated that partitioning the property would negatively impact mining operations' costs and efficiency. The trial court ruled that equitable division was unfeasible due to differing views on the property's use and ordered the property sold. On appeal, Steadman raised procedural issues regarding the trial court's consideration of Uptown Motors' contract to deed interests back to Lollar, Myers, and Spain. The court found that Steadman had not argued the contract's validity at trial, thus that issue was not reviewed on appeal, adhering to the precedent that unaddressed matters cannot be raised for the first time in appeals (Andrews v. Merritt Oil Co., 612 So.2d 409 (Ala.1992)).

The trial court determined that only Steadman and Uptown Motors had interests in the property, making them the necessary parties for resolving the dispute. Steadman contended that the evidence did not support the trial court's finding that the property could not be equitably divided, challenging the court's order for sale. The supreme court has upheld decisions where properties of varied topography or small joint interests were found not to be equitably divisible, citing cases such as Williams v. McIntyre and Irons v. Le Sueur. Conversely, the court has reversed sales orders when the evidence did not substantiate the trial court’s conclusion regarding equitable division, as seen in Murphy v. Dees and Fendley v. Lambert.

In this case, Uptown Motors had the burden to prove the property could not be equitably divided. Evidence presented indicated the property lacked access to a paved road, was unimproved, and had uniform topography. While Steadman testified that the property could be divided, testimonies from Justice and Ingle suggested any division would create economic inefficiencies for Uptown Motors' mining plans. However, the record did not support the notion that the property could not be partitioned based on its nature or use; instead, it indicated that partitioning to reflect Steadman's interest would be economically inefficient, which did not meet the necessary burden of proof for sale. Consequently, the evidence was deemed insufficient to uphold the trial court's finding, leading to a reversal and remand for further proceedings.