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Facts

  • The case involves the Grissoms' attempt to set aside a quitclaim deed for mineral interests in New Mexico, executed by their aunt, Genevieve (Trixie) Wilkinson, to her stepson, Joel Wilkinson. The Grissoms accused Joel of exploiting Trixie's old age and frail health to obtain the deed. Joel contended that the deed was intended to correct an error in interpreting the law relative to his father's will, ensuring he received what his father intended (paras 2-3).

Procedural History

  • Oklahoma probate court, December 2004: Dismissed the Grissoms' counterclaim for lack of subject matter jurisdiction due to the mineral interests being located in New Mexico (para 3).
  • District Court of San Juan County, (N/A): Consolidated the Grissoms' separate action to set aside the quitclaim deed with Joel's creditor's claim in New Mexico (para 4).

Parties' Submissions

  • Petitioners-Appellants (The Grissoms): Argued that Joel Wilkinson abused his relationship with Trixie Wilkinson by taking advantage of her old age and frail health to cause her to deed him the New Mexico mineral interests. They also attempted to present an undue influence claim that was not explicitly pled in their petition (paras 2, 5, 8).
  • Respondents-Appellees (Joel Wilkinson and Co-Trustees): Contended that Trixie intended to execute the quitclaim deed to correct an error made by her late husband’s lawyers in interpreting the law relative to her husband’s will, to ensure Joel received what his late father had intended (para 2).

Legal Issues

  • Whether the district court erred by not allowing the Grissoms to present an undue influence claim that was not explicitly pled in their petition or to amend their petition after trial to include a separate undue influence claim (para 1).
  • Whether the district court erred in granting Joel Wilkinson Jr.’s creditor’s claim (para 1).

Disposition

  • The Court of Appeals affirmed the district court's judgment denying the Grissoms' petition to set aside a quitclaim deed for fraud and constructive trust, denying their post-trial motion to amend their petition, and granting in part Joel W. Wilkinson Jr.’s creditor’s claim (para 1).

Reasons

  • The Court of Appeals held that the district court did not commit reversible error in refusing to allow the Grissoms to present a claim for undue influence at trial. The court found that the Grissoms failed to preserve their argument regarding the creditor’s claim and thus would not consider it. The court reasoned that the district court made unchallenged findings that would preclude the Grissoms from prevailing on an undue influence claim and that the Grissoms failed to demonstrate how the exclusion of evidence on undue influence prejudiced them. Furthermore, the court found that allowing the Grissoms to amend their petition post-trial would be futile in light of the district court's findings. The court concluded that there was no reversible error in the district court's rulings (paras 8-25).
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