Ronald and Bonnie Sutton purchase some acreage in Arkansas from the Whites in 1987. The 1987 deed reserves 50% of the mineral rights. The deed is held in escrow. Lonnie and Lorene Sutton—Lonnie being Ronald and Bonnie's son—pay half the down payment and contribute to the monthly payments. Their names, however, do not appear on the original deed. Two years after the purchase and prior to the recording of the deed, their names are added as grantees by interdelineation. There is no evidence as to which of the parties made the alteration. Simultaneously, a mortgage is issued on the property showing Lonnie and Lorene as the owners. After a divorce between Lonnie and Lorene, Ronald and Bonnie convey a 50% interest in the surface rights to Lonnie reserving: "an undivided one-half interest in and to all of the oil, gas coal and other minerals . . ." Lonnie then, by quitclaim deed, conveys his interest to Lorene which contains a similar reservation of mineral rights. Ronald and Bonnie argue that the 1996 deed puts Lonnie on notice that he is not receiving any mineral rights. They testify as to their subjective intent in executing the 1996 deed.
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