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Devon Energy Production Company, L.P. v. McClure Oil Company, Inc.
The Eastland Court of Appeals reversed and remanded a trial court's final judgment in a complex royalty interest dispute, holding that the judgment was not supported by the pleadings of the successors to a later-recorded deed who had asserted only trespass-to-try-title claims. The decision arose from an interpleader action involving competing claims to royalty interests in Glasscock County property, all tracing back to a common predecessor-in-interest who executed two deeds conveying overlapping interests but recorded them in the opposite order.
Analysis
Eastland Court Reverses Title Judgment Where Trespass-to-Try-Title Pleadings Failed to Support Award of Nonpossessory Royalty Interests
Devon Energy's interpleader action to resolve competing royalty claims stemming from two deeds executed in one order but recorded in reverse order resulted in a final judgment that the Eastland Court of Appeals reversed for failure to support the judgment with proper pleadings. The Court held that the trial court's award of title to nonpossessory royalty interests was not supported by the successors' pleadings, which primarily relied on trespass-to-try-title claims rather than declaratory relief.
Eastland Court Reverses Title Judgment Based on Trespass-to-Try-Title Pleading Defects for Nonpossessory Mineral Interests
The Eastland Court of Appeals reversed and remanded a trial court's final judgment in a complex royalty interest dispute, holding that the judgment was not supported by the pleadings of the successors to a later-recorded deed who had asserted only trespass-to-try-title claims. The decision arose from an interpleader action involving competing claims to royalty interests in Glasscock County property, all tracing back to a common predecessor-in-interest who executed two deeds conveying overlapping interests but recorded them in the opposite order.