Bates v. Old Mac Coal Co‪.‬

1 In 1918 Emma Arnall and Elizabeth MacFate resided in Washington, D.C., where they were government employees. They had acquired the land (80 acres) herein involved by government patent, issued on behalf of the Chickasaw and Choctaw Indian Nations, conveying fee-simple title subject only to the governments reservation of the coal and asphalt rights in the land. December 24, 1918, the patentees conveyed the land by warranty deed to J.J. Noah, the deed containing the following reservations: