Cuprite Mine Partners v. Anderson, No. 13-16657 (9th Cir. 2015)
Annotate this CaseThis appeal arose from a dispute over interests in mining claims originally owned by Guy Anderson and bequeathed to his six children upon his death. The court concluded that the district court did not abuse its discretion in allowing all defendants to be joined in a single partition action. In this case, the district court acted well within its discretion in concluding that a single partition action was the most expeditious way of resolving this dispute, and in allowing all defendants to be joined in that action. The court also concluded that the district court did not err when it granted summary judgment in favor of Cuprite and ordered partition by sale to Freeport; the district court properly concluded that partition by sale was more appropriate than partition in kind; and accepting the current offer or any better terms that could be had was a reasonable way for the district court to structure the partition sale, and does not violate any terms of the operative statute. Finally, the court concluded that, regardless of whether an Arizona state court would have been required to hold a trial, the district court correctly resolved the summary judgment motion according to the Federal Rules of Civil Procedure. Accordingly, the court affirmed the judgment.
Court Description: Arizona Law / Mining Claims. The panel affirmed the district court’s summary judgment, and held that the district court properly applied Arizona substantive law regarding partition of mining claims and federal procedural standards for summary judgment. Plaintiff is a limited liability company formed by children of Guy Anderson (or their successors-in-interest) who wished to sell their interests in Guy’s mining claims on a piece of property in Arizona’s Copper Mountain Mining District, and the defendants were Guy’s remaining child, and his children, who did not want to sell their interest in the mining claims. The district court entered judgment ordering partition by sale, and approved the sale of the property. CUPRITE MINE PARTNERS V. ANDERSON 3 The panel held that the district court did not abuse its discretion in allowing all of the defendants to be joined in a single partition action. The panel held that the district court did not err in granting summary judgment in favor of plaintiff. As an initial matter, the panel held that plaintiff had a legal right to partition under Arizona law which gives any owner or claimant of property held in cotenancy the right to compel partition without regard to the preferences of other owners or claimants. The panel also held that the district court properly concluded that partition by sale was more appropriate than partition in kind. The panel further held that the district court reasonably structured the partition sale, and the sale did not violate any terms of the operative Arizona statute. The panel held that the district court properly resolved the summary judgment motion according to the Federal Rules of Civil Procedure. Specifically, the panel held that even if Arizona law prohibited summary judgment and instead required a trial in a suit for partition by sale, such a suit was procedural in nature and a federal court sitting in diversity was required to follow federal, not state, procedural rules. The panel held that according to the facts as presented on summary judgment the outcome – partition by sale – would have been identical even if the district court had held a trial. The panel concluded that the district court properly granted relief on summary judgment where there was no genuine dispute of material fact to be resolved at trial. 4 CUPRITE MINE PARTNERS V. ANDERSON
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