Copeland Sand & Gravel, Inc. v. Estate of Angeline Dillard

Where there is a dispute over the meaning of a mineral reservation contained in a deed, the term must be analyzed using the three Yogman factors.

Copeland Sand & Gravel, Inc. (Copeland) and the Estate of Angeline Dillard (Estate), with Richard Skidmore (Skidmore), disputed the scope of a mineral rights reservation executed in 1954 by Angeline Dillard that conveyed 120 acres to Sunny Valley Lumber Company subject to a reservation of mineral rights. The reservation did not specify the meaning of “minerals.” Copeland acquired the deed to the property while Skidmore acquired the mineral rights. Copeland intended to use the property as a source of rock and gravel for construction purposes, and filed suit to quiet title and obtain specific declaratory relief regarding the meaning of the reservation of rights. Both parties filed for summary judgment; the trial court granted Copeland’s motion, denied Skidmore’s motion, and granted Copeland’s requested declaratory relief. The Court applied the three-step Yogman analysis to analyze the mineral reservation. First, the Court held that the term was ambiguous because both parties had plausible interpretations of the definition of the word “mineral.” Because both parties agreed there was no relevant extrinsic evidence of the intent of the contracting parties, the Court moved on to the third step, which is to look to maxims of construction. The Court held that the general rule is to construe the contract against the grantor (Copeland) and where there are equally proper constructions, the construction that is most favorable to the party in whose favor the provision was made (Skidmore) should prevail. The Court reversed and remanded judgment for Copeland as to the declaration regarding the scope of the mineral rights reservation, and otherwise affirmed.