Energy Environmental Blog

Supreme Court of Ohio Further Clarifies Exception Under the Marketable Title Act in Erickson v. Morrison

Written by Mark Hylton | Mar 17, 2021 6:27:36 PM

On March 16, 2021, the Supreme Court of Ohio expanded upon its prior decision in Blackstone v. Moore, 2018-Ohio-4959, holding that a reference in a deed that described a previously severed mineral interest, but without identifying the name of the interest owner, was specific under R.C. 5301.49(A), and thus prevented the extinguishment of the interest under the Marketable Title Act.  See Erickson v. Morrison, Slip Opinion No. 2021-Ohio-746.  Read more about that decision in our Client Alert.