Hauer v. Zerr, et al.
Annotate this CaseCraig Hauer appealed the dismissal of complaint seeking reformation of a deed to secure hunting access to property he had conveyed to Kurt and Lois Zerr. In 2013, Hauer sold land to the Zerrs. The parties’ contract and deed both include language reflecting the parties’ intent to allow Hauer to reserve hunting access to the land. Hauer accessed the land to hunt pursuant to the reservation until the Zerrs, believing the reservation to be unenforceable pursuant to N.D.C.C. 47- 05-17, denied Hauer access to the property. Hauer initiated this action seeking to reform the deed to reflect the parties’ intent to allow Hauer access to the property. The North Dakota Supreme Court concluded the district court correctly dismissed Hauer’s complaint seeking reformation of the deed and affirmed the district court.
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