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 and that extrinsic evidence was properly admitted to determine the parties' intent, and that the four‑year statute of limitations for reformation did not bar the claim as a matter of law. A dissent argued the deed was unambiguous and that the limitations period should bar reformation.