## Facts

- Claude R. Butler owned land acquired through predecessors who purchased state-owned lands by public sale and received three patents from the State of Oklahoma, acting through the Commissioners of the Land Office.
- Each patent (and the sale notice) reserved to the State an undivided 50% interest in “all oil, gas and other mineral rights” (or similar wording).
- Butler sued to quiet title to the coal and to minerals other than oil and gas, asserting the reservation did not include coal.
- The Commissioners counterclaimed to quiet title in the State’s asserted coal interest, contending “other mineral rights” included coal.
- Butler moved for summary judgment, arguing Oklahoma law gives the phrase “oil, gas and other minerals” a settled meaning limited to oil and gas and minerals produced as their components or constituents, excluding coal.
- The Commissioners argued the reservation was ambiguous and sought extrinsic evidence of the parties’ intent.
- The district court held the reservation unambiguous, refused extrinsic evidence, and granted summary judgment for Butler quieting title to the coal in him.
- The Commissioners appealed.

## Issues

1. Whether a patent reservation of “oil, gas and other mineral rights” includes coal under Oklahoma law.
2. Whether the reservation language is ambiguous such that extrinsic evidence of intent is admissible.

## Decision

- The Oklahoma Supreme Court affirmed summary judgment for Butler.
- The court held that a reservation of “oil, gas and other mineral rights” does not include coal.
- The court agreed the reservation language was unambiguous and declined to admit extrinsic evidence to expand its meaning.
- The court relied on a long and uniform line of Oklahoma decisions construing similar language as limited to the oil-and-gas estate and related substances.

## Legal Principles

- In Oklahoma, the phrase “oil, gas and other minerals” (or “oil, gas and other mineral rights”) has a settled legal meaning tied to the oil-and-gas estate and does not, without more specific language, include coal.
- When reservation language has an established legal meaning and is unambiguous on its face, courts do not admit parol evidence to vary or enlarge the reservation.
- A reservation that specifically names “oil” and “gas” followed by “other minerals” is construed in line with that technical usage, rather than as a blanket reservation of all minerals including solid minerals such as coal.

## Conclusion

The court affirmed a judgment quieting title to coal in the landowner, holding that Oklahoma’s settled interpretation of “oil, gas and other mineral rights” excludes coal and that the unambiguous reservation language could not be expanded through extrinsic evidence.


Okla. ex rel. Comm’rs of the Land Off. v. Butler, 753 P.2d 1334 (Okla. 1987)