Alcott v. 1893 Oil and Gas: Statute of Frauds Bars Mineral Interest Claim Based on Ambiguous 1922 Deed Description

The Corpus Christi Court of Appeals affirmed summary judgment against heirs claiming mineral interests in Live Oak County acreage under a 1922 deed that purported to convey mineral rights across 2,092.08 acres, where the grantor never held title to the entire tract. The appellants challenged both the denial of their summary judgment motion and the grant of summary judgment to the mineral interest holders who acquired rights through subsequent special warranty deeds.