Carl Miles v. J. O. Martin

Summary

The Texas Supreme Court reversed the lower courts and remanded for a new trial to determine whether respondent J. O. Martin is entitled to equitable relief (reformation or a constructive trust) of a one‑fourth mineral interest. The Court held that the Duhig rule applies to the 1951 deed, that the deed of trust cannot be read into the deed to limit the conveyance, and that the record instruments do not establish Martin's ownership of the mineral interest. The dissent argued that Miles had notice of Martin's claim and was not an innocent purchaser.