Carl Miles v. J. O. Martin

Summary

The Texas Supreme Court reversed the Court of Civil Appeals and remanded the case for a new trial to determine whether respondent Martin is entitled to a one‑fourth mineral interest and any equitable relief. The Court applied the Duhig rule, held that the deed of trust does not alter the reservation, and found no record establishing Martin's ownership. Justice Griffin dissented, arguing that Miles had notice of Martin's claim and was not an innocent purchaser. The dissent would have affirmed the lower courts.