Anadarko Land Corp. v. Family Tree Corp.Annotate this Case
The parties in this case disputed title to certain mineral interests underlying certain property. The dispute arose out of a 1911 Laramie County tax assessment against Union Pacific’s mineral interests in the property and the county’s subsequent tax sale and issuance of a tax deed for the property. Family Tree Corporation, which claimed title to portions of the minerals, filed a complaint for quiet title and declaratory judgment against Three Sisters LLC, which also claimed an ownership in the minerals, and Anardarko Land Corporation. The district court quieted title to Family Tree based upon the 1912 tax sale. Anadarko appealed, arguing that the 1911 tax assessment against the minerals was unconstitutional, and therefore, the resulting tax sale and deed were void. The Supreme Court affirmed after drawing the line between a tax assessment defect that will render a tax deed void and one that will render the tax deed viable, holding (1) the error in Laramie County’s tax assessment against the minerals at issue rendered the resulting tax deed voidable, not void; and (2) accordingly, Anadarko’s challenge to the validity of the tax deed was barred by the statute of limitations.