Sixth Court Reverses Summary Judgment in Tax Foreclosure Dispute Over Sheriff's Deed Ambiguity in Harrison County Mineral Interests

The Texarkana Court of Appeals reversed a trial court's summary judgment that barred claims under the Texas Tax Code statute of limitations, finding genuine issues of material fact regarding whether a Sheriff's Deed following a $4,500 tax foreclosure sale conveyed only wellbore-specific royalty interests in three pooled units or broader mineral interests across seven Harrison County tracts. Appellants Obra J. Moore, III and affiliated entities argued the deed conveyed interests limited to specific API-numbered wells in the Minnie Bell Gas Unit, A.G. Birdwell Gas Unit, and J. Johnson A-1 Unit, while appellee 1789 Minerals Fund I, LP claimed broader mineral estate ownership through its chain of title from tax sale purchaser Regina Roberts.