This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
- The case revolves around a dispute over title to two properties in New Mexico, originally owned by Nicolas Sanchez, who conveyed his interest to his son Phil Sanchez, Phil's brother Fidel, and Fidel's wife Gloria, with a restriction on future conveyances. After Fidel's death, Gloria sold her interest to Phil and Tessie Sanchez under a warranty deed and installment payment agreement, with the understanding that their son David would pay the installments to purchase Gloria’s half-interest, which would then be conveyed to him. Despite a restriction on direct sales to David due to the original deed, a 1996 deed from Gloria to Phil and Tessie did not apply this limitation. David paid the installments, and in 2005, a warranty deed was executed to include David for the purpose of obtaining cattle permits. In 2015, Phil and Tessie filed a lawsuit to quiet title against David, claiming the conveyance was intended to be temporary for grazing permit purposes, which David and his wife Barbara contested, claiming a permanent one-half interest (paras 2-3).
Procedural History
- [Not applicable or not found]
Parties' Submissions
- Plaintiffs (Phil and Tessie Sanchez): Argued that the conveyance of interest in the properties to David was intended to be temporary, solely for the purpose of obtaining grazing permits from the United States Forest Service, and that David was expected to convey the properties back to them afterward.
- Defendant/Counterplaintiff (David Sanchez and Barbara Sanchez): Contended that David owned a one-half interest in the properties and that Barbara, as David's wife, owned a community interest. They argued that the 1996 deed and subsequent payments for Gloria’s interest were intended to permanently transfer a one-half interest in the properties to David (paras 3-4).
Legal Issues
- Whether the district court erred in characterizing the Plaintiffs' quiet title claim as a fraud claim subject to a four-year statute of limitations.
- Whether the application of equitable estoppel to preclude the Plaintiffs' denial of David’s interest in the Properties was appropriate (para 5).
Disposition
- The district court's final judgment dismissing the Plaintiffs' complaint for quiet title and other relief with prejudice and awarding costs to the Counterclaimants was affirmed (para 1).
Reasons
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The Court of Appeals, with Judge Megan P. Duffy writing and Judges Linda M. Vanzi and Zachary A. Ives concurring, affirmed the district court's decision on several grounds. The court found the Plaintiffs' appeal moot because they did not challenge the district court's ruling in favor of David on his counterclaim for quiet title, which decided the merits of the property ownership. The court also noted that issues raised in the docketing statement but not argued in the brief in chief are deemed abandoned. The Plaintiffs' failure to adequately challenge the district court's findings and judgment in favor of David on his counterclaim rendered their appeal of the dismissal of their claims moot. The court further declined to review the case under exceptions for mootness, such as matters of substantial public interest or issues capable of repetition yet evading review, finding that the Plaintiffs did not demonstrate applicability of these exceptions. Lastly, the court found no abuse of discretion in the district court's award of costs to the Counterclaimants as the prevailing party (paras 5-9).
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