Robert A. Brown, Petitioners v. Benjamin Havard, Respondents

Summary

The Texas Supreme Court affirmed the Court of Civil Appeals, holding that the royalty reservation in the Browns' deed was ambiguous, allowing extrinsic evidence, and that the reservation amounted to a one‑sixteenth royalty, not a half royalty. The Court also held that the four‑year statute of limitations for reformation begins when the mistake is or should be discovered, so the claim was not barred. The judgment awarding the Browns a one‑sixteenth royalty was therefore affirmed.