Eastland Court Holds Deed of Trust Excluded Mineral Estate Based on Partition Deed and Express Reservation Language

The Eastland Court of Appeals affirmed summary judgment that a deed of trust securing a loan unambiguously excluded the mineral estate where the legal description stated "surface rights only" and was subject to "all outstanding oil, gas, and other minerals." The court applied the rule that specific provisions control over general boilerplate language, holding that Exhibit A's express limitations prevailed over the preprinted form's broad conveyance language.