Baker v. Baker (In the Matter of Baker)

No. 14-10569 (non-precedential)
Fifth Circuit AFFIRMED lower courts' rulings that bankruptcy court could exercise jurisdiction to interpret and enforce its own prior sale order. District Court further did not commit err by affirming bankruptcy court's denial of the motion to amend a prior deed where the purchaser knew about the ex-spouse's interests in the property at the time of the conveyance. The underlying dispute over the impact of the ex-spouse's residual interest in the property remained an issue to be decided by the state court in the divorce proceeding.
Procedural context:
Appeal from an order of the district court affirming an order of the bankruptcy court holding that it could exercise jurisdiction over a motion to interpret and enforce its own prior sale order concerning a dispute between a non-debtor purchaser and a non-debtor ex-spouse of the debtor (who claimed a competing interest in the assets acquired by the purchaser).
Debtor filed bankruptcy shortly after he and his wife commenced divorce proceedings in state court. In the divorce proceeding, the spouse agreed that the debtor could keep certain real estate as his own separate property, but the form of deed severed the mineral interests from the land and reserved those interests for the wife. In the bankruptcy, the debtor sold the property to the purchaser, but the purchaser later discovered that the ex-wife continued to assert an interests in the minerals. The purchaser filed a motion to compel in the bankruptcy court, and asked for the deed to be amended to convey the ex-wife's interests in the property in conformity with what the purchaser believed he was buying. The bankruptcy court exercised jurisdiction over the motion to compel, but denied the relief requested because the purchaser was aware of the mineral severance at the time he purchased the asset from the debtor. The purchaser appealed, and the district court affirmed.
KING, DAVIS, and OWEN (per curiam)

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