King Ranch, Inc. v. Chapman
King Ranch, Inc. v. Chapman, 2003 Tex. LEXIS 242 (2003)
Facts
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The Chapman heirs alleged a conspiracy between King and Kleberg to deprive them of title.
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In 1853, the Mendiola heirs transferred their interest to Captain Richard King.
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Helen Chapman died in 1881, and John Rankin was substituted as plaintiff.
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Major Chapman died in 1859, leaving his estate to his wife Helen.
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The court of appeals found evidence of extrinsic fraud based on Kleberg's representation of King, the Lewis deed, the Powers letter, payment for the Rincon, and probate court approval.
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Helen Chapman alleged in her original petition that Richard King ejected her from the premises in 1877.
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Kleberg's law firm represented King in unrelated matters while Cause No. 1279 was pending.
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King conveyed a one-half interest to Gideon Lewis and later a one-fourth interest to Major William Warren Chapman.
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Kleberg later became the manager of the King Ranch and married King's daughter.
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King Ranch has cultivated, used, and enjoyed the Rincon for over a hundred years.
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In 1879, Helen Chapman sued King in trespass to try title, seeking an undivided one-half interest in the Rincon.
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The Texas Supreme Court found that none of this evidence supported an inference of extrinsic fraud.
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In 1883, the parties settled Cause No. 1279, with King paying the Chapman estate $5,811.75 and the Chapman estate conveying their interest in the Rincon to King.
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In 1995, the Chapman heirs sued to set aside the 1883 judgment and asserted a trespass to try title action, alleging a conspiracy between King and Kleberg.
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The State of Texas issued a patent to the heirs of Juan Mendiola for 15,449.4 acres of land in Nueces County, known as the Rincon de Santa Gertrudis.
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The 1883 judgment vested all right, title, and interest in the Rincon in Richard King.
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Lewis's interest was sold back to King and Chapman jointly.
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The Lewis deed was not recorded until 1904 by Kleberg's nephew.
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Key Holdings
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King Ranch satisfied the requirements of the statute and proved adverse possession of the Rincon as a matter of law.
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The Chapman heirs failed to produce even a scintilla of evidence of Richard King's alleged extrinsic fraud, and therefore their bill of review fails.
Citations
King Ranch, Inc. v. Chapman, 2003 Tex. LEXIS 242, 46 Tex. Sup. Ct. J. 1093, 2003 WL 22025017, 118 S.W.3d 742 (2003)
Legal Reasoning
The court reasoned that the Chapman heirs failed to provide sufficient evidence of extrinsic fraud to justify a bill of review. The court also held that King Ranch established adverse possession as a matter of law, due to the repudiation of the co-tenancy relationship and the continuous use and enjoyment of the property for over a hundred years.
Outcome
The Texas Supreme Court reversed the court of appeals' judgment and rendered judgment that the Chapman heirs take nothing.
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