## Facts

- An estate owned approximately 4,000 acres in LeFlore County, Oklahoma.
- Before selling the land, the estate’s executors executed coal mining leases in favor of Heatherly Mining, Inc.; the probate court confirmed the leases, but they were not recorded with the county clerk.
- The estate conveyed the land to buyers by deed that (1) reserved to the seller a non-participating royalty interest in one-half of the minerals and (2) stated that mineral interests covered by a “valid, recorded lease” would not vest in the buyers until lease expiration or termination; it also addressed top leases “validly recorded or confirmed by the probate court” with a similar vesting delay.
- The buyers claimed entitlement to royalty proceeds from the coal leases, arguing that the unrecorded leases were not “valid, recorded” leases under the deed and therefore the affected one-half mineral interests vested immediately upon conveyance.
- The estate counterclaimed for reformation, alleging the deed failed to reflect the parties’ actual agreement that the estate would retain royalty interests under the existing coal leases until they expired, and offered parol evidence to prove that understanding.
- The trial court excluded the estate’s parol evidence as an improper attempt to vary an unambiguous deed, denied reformation, and quieted title in the buyers.
- The court of appeals affirmed; the Oklahoma Supreme Court granted certiorari.

## Issues

1. Whether parol evidence is admissible in an action seeking reformation of a deed to show the writing does not reflect the parties’ true agreement due to mistake or other equitable grounds.
2. Whether the trial court erred by applying the parol evidence rule to exclude evidence offered to support the estate’s reformation counterclaim.

## Decision

- The Oklahoma Supreme Court vacated the court of appeals’ opinion, reversed the trial court’s judgment, and remanded.
- The Court held that when reformation of a written instrument is sought, parol evidence is admissible.
- The Court concluded the trial court misapplied the parol evidence rule by excluding extrinsic evidence solely because it conflicted with the deed’s text.
- The Court did not decide who ultimately owned the disputed royalty interests; it required further proceedings with the proffered evidence considered on the reformation claim.

## Legal Principles

- Reformation is an equitable remedy that corrects a written instrument to conform to the parties’ actual agreement; it does not create a new agreement.
- The parol evidence rule does not bar extrinsic evidence offered to prove that, because of mutual mistake or similar equitable basis, the writing fails to express the true agreement and should be reformed.
- A court commits error by refusing to hear parol evidence supporting reformation on the ground that the writing is unambiguous or that the evidence contradicts the instrument, because contradiction is inherent in a claim that the writing is mistaken.

## Conclusion

The Oklahoma Supreme Court held that parol evidence is admissible to support a claim for reformation of a deed and reversed a judgment that excluded such evidence; the case was remanded for the trial court to consider the extrinsic evidence and determine whether reformation is warranted and how that affects the disputed royalty interests.


Thompson v. Estate of Coffield, 894 P.2d 1065 (Okla. 1995)