Post-Execution Mineral Reservation Invalidated: O'Neal v. Ball and the Limits of Deed Alteration

Church trustees successfully challenged a mineral reservation that the grantor inserted into a deed after the notarial certificate showed he had already executed and acknowledged the instrument on April 20, 1953. The Court of Civil Appeals held that the grantor could not validly add the reservation post-execution and that the trustees' failure to discover the fraudulent insertion for six years was excused under the four-year statute of limitations where the deed was never physically delivered but remained with the abstract company.