## Facts

- Landowners filed a 1994 quiet title action involving five tracts in Weld County, Colorado.
- The parties were successors to deeds executed between 1906 and 1909 by the Union Pacific Railroad Company.
- The deeds conveyed surface estates but reserved minerals to the grantor’s successor in two forms:
  - “all coal and other minerals within or underlying said lands” (three deeds)
  - “all oil, coal and other minerals” (two deeds)
- The landowners claimed the “coal and other minerals” reservations were ambiguous and did not include oil and gas, and sought to quiet title to the oil and gas interests.
- Union Pacific Resources Company (UPRC) asserted the reservations included oil and gas, giving it the oil and gas estate.

## Issues

1. Under Colorado law, does a deed reservation of “all coal and other minerals” (or “other minerals”) include oil and gas as a matter of law?
2. If “other minerals” is unambiguous in this context, may a court consider extrinsic evidence of historical context or alleged party intent to exclude oil and gas?

## Decision

- The Colorado Supreme Court affirmed the court of appeals and the trial court’s summary judgment for UPRC.
- The court held Colorado follows the majority rule that a reservation of “other minerals” includes oil and gas.
- The court rejected the landowners’ ambiguity argument and declined to allow extrinsic evidence to alter the established legal meaning of the reservation language.
- As a result, UPRC retained ownership of the oil and gas interests reserved by the deeds.

## Legal Principles

- In Colorado, absent limiting language, a deed reservation of “minerals” or “other minerals,” including “all coal and other minerals,” reserves oil and gas.
- Deed interpretation in mineral conveyancing applies objective legal meaning when controlling precedent and settled usage treat oil and gas as minerals.
- When reservation language is unambiguous under governing law, extrinsic evidence of subjective intent or localized historical understanding is not used to contradict that meaning.
- Courts favor certainty and stability in land titles and are reluctant to disturb settled rules of property that affect long-standing conveyances.

## Conclusion

Colorado treats oil and gas as included within deed reservations of “other minerals,” so the early-1900s reservations at issue preserved the oil and gas estate for UPRC rather than the surface owners.


McCormick v. Union Pac. Res. Co., 14 P.3d 346 (Colo. 2000)