Blackstone v. Moore (Slip Opinion)

*449{¶ 1} Ohio's Marketable Title Act generally allows a landowner who has an unbroken chain of title to land for a 40-year period to transfer title free of any interests that existed prior to the beginning of the chain of title. Under the act, however, an earlier-created interest is preserved if sufficient reference is made to the interest within that chain of title. The question we must answer is what type of reference is sufficient to preserve that interest.

{¶ 2} The landowners here seek to extinguish an oil-and-gas royalty interest created in 1915. A deed in their chain of title references…