Utah Court of Appeals
When can Utah courts reform deeds for mutual mistake? Peterson v. Pierce Explained
Summary
Peterson sued for access to her property via a two-rutted lane after the Pierces erected a fence blocking her use of the lane. The district court found mutual mistake in the original deeds regarding the location of a joint driveway easement and reformed the deeds to clarify that the joint driveway was the existing two-rutted lane, not a seven-foot strip as described in the deed.
Practice Areas & Topics
Analysis
In Peterson v. Pierce, the Utah Court of Appeals addressed when courts may reform deeds based on mutual mistake and the scope of such reformation. The case provides important guidance for practitioners handling easement disputes and deed reformation claims.
Background and Facts
The Peterson and Pierce parcels were previously under common ownership by the Hatton family. When the Hattons conveyed parcels to the Pierces in 1989 and 1997, the deeds included easements described as “joint driveways” over seven-foot strips. However, for over 50 years, both families had used a two-rutted lane as the actual joint driveway. After Peterson acquired her parcel in 1997, she continued using the two-rutted lane until the Pierces erected a fence in 2013, blocking her access.
Key Legal Issues
The case presented three main issues: whether Peterson’s reformation claim was barred by the statute of limitations or laches, whether the deeds contained a mutual mistake warranting reformation, and whether the district court properly awarded attorney fees under the lis pendens statute.
Court’s Analysis and Holding
The Court of Appeals affirmed that mutual mistake existed, noting the parties intended the “joint driveway” language to refer to the historically-used two-rutted lane, not the seven-foot strips described in the deeds. The court found the three-year statute of limitations began running in 2013 when the Pierces blocked access, not in 1997 when the survey was completed, because Peterson continued using the lane without interference until then.
However, the court found error in the district court’s reformation. While correctly identifying mutual mistake, the reformed deeds failed to include the seven-foot frontage easement that all parties agreed was also intended. The court remanded for proper reformation recognizing both the two-rutted lane easement and the frontage easement.
Practice Implications
This decision demonstrates that extrinsic evidence of the parties’ actual intent can overcome seemingly clear deed language when mutual mistake is proven by clear and convincing evidence. Practitioners should carefully ensure that reformed deeds address all easements the parties intended to create, even those not directly disputed. The case also shows that statute of limitations periods for mutual mistake claims may not begin running until the claiming party is actually prevented from exercising their rights.
Case Details
Case Name
Peterson v. Pierce
Citation
2019 UT App 48
Court
Utah Court of Appeals
Case Number
No. 20160778-CA
Date Decided
March 28, 2019
Outcome
Affirmed in part and Reversed in part
Holding
The district court correctly found mutual mistake requiring deed reformation but erred by failing to include the seven-foot frontage easement in the reformed deeds.
Standard of Review
Correctness for legal determinations including statute of limitations and laches application; clearly erroneous for findings of fact in both law and equity cases; correctness for conclusions of law in equity cases; correctness for attorney fee awards as matters of law, but abuse of discretion where fees are predicated upon findings of fact
Practice Tip
When seeking deed reformation for mutual mistake, ensure the reformed deed includes all easements the parties intended to create, even if not directly at issue in the litigation.
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