Full opinion text
McHUGH, Circuit Judge. I. INTRODUCTION This case involves a dispute over the ownership of mineral rights appurtenant to several tracts of land located in Haskell County, Kansas, as well as the royalties due on those mineral rights. Michael Leathers and his brother Ronald Leathers each inherited half of these mineral rights from their mother. But an error in a quit claim deed subsequently executed between the brothers left it unclear whether Ronald’s one-half interest in the mineral estate had been conveyed to Michael. In January 2007, Michael filed a lawsuit seeking to quiet title to the disputed one-half interest and related royalties. As defendants, Michael named Ronald; Ronald’s ex-wife, Theresa Leathers; James Holden, as Trustee for an entity called the Dirt Cheap Mine Trust; various energy companies, as producers of natural gas from the mineral rights; and the United States, on behalf of the Internal Revenue Service (“IRS”), as a holder of tax liens on any property owned by Ronald. In a series of orders spanning several years, the district court (1) reformed the quit claim deed to reflect that Ronald had reserved his one-half interest in the mineral estate; (2) awarded half of Ronald’s one-half interest (i.e., a one-quarter interest) to Theresa, pursuant to Ronald and Theresa’s divorce decree; and (3) held that Ronald owed approximately $1.5 million to the IRS and that the IRS’s tax liens had first priority to any present and future royalties due to Ronald from his remaining one-quarter mineral interest. Ronald filed a timely appeal (Case No. 15-3264), and Holden and Joe Alfred Izen, Jr., the attorney for the Dirt Cheap Mine Trust, filed a separate appeal (Case No. 15-3280). The appeals were briefed and argued separately, and they largely raise independent issues. Nonetheless, because both appeals arise from a common, complicated factual and procedural background, we consolidate them for disposition and consider both appeals in this Opinion. For the reasons set forth below, we affirm the district court’s judgment on all grounds. II. BACKGROUND A. Factual History 1. The Mineral Interests Michael Leathers and Ronald Leathers are brothers, and Louise Leathers was their mother. Louise owned 2.5 sections of land in Haskell County, Kansas (the “Property”). In 1973, Michael, Ronald, and Louise signed a partnership agreement forming a general partnership called the Leathers Land Company. Louise transferred the surface estate of the Property to the partnership, but she reserved ownership of the appurtenant mineral estate. When Louise died in 1991, ownership of the mineral estate passed to Michael and Ronald in equal shares. Michael and Ronald also each became 50 percent owners of the Leathers Land Company. In 1996, Michael invoked a mutual buyout provision of the partnership agreement in order to purchase Ronald’s 50 percent share of the Leathers Land Company’s assets. This move led to a dispute between the brothers which ended in a state-court judgment ordering Ronald to convey his 50 percent interest in the surface estate of the Property to Michael. On May 11, 1998, Ronald signed a quit claim deed (the “Quit Claim Deed” or the “Deed”) which transferred all of Ronald’s interest in the Property to Michael. Critical here, the Deed did not expressly reserve Ronald’s 50 percent interest in the Property’s mineral estate. The Deed was recorded in Haskell County. In June 2000, Ronald’s -wife, Theresa Leathers, filed for divorce in Kansas state court. In connection with the divorce, Theresa filed a Notice of Lis Pendens with the Register of Deeds in Haskell County, specifically referencing the Property. While the divorce was pending, Michael began hearing from several energy companies about issues with the title to the mineral rights in the Property. In September 2000, a representative from Chesapeake Energy Company (“Chesapeake”) told Michael that the Deed had not reserved to Ronald any mineral rights appurtenant to the Property. The representative tried to contact Ronald as well, but Ronald did not respond. In October 2001, Anadarko Petroleum Corporation (“Anadarko”) contacted Michael about future royalty payments on production from a new well. A division order included in the correspondence stated that Ronald held “no interest” in the mineral rights appurtenant to the Property, that Michael owned 50 percent of the rights, and that another entity owned the other 50 percent. Anadarko asked Michael to make any necessary corrections to the division order before signing and returning it. Michael edited the division order to show that he and Ronald each owned 50 percent of the mineral rights, and he sent it to Anadarko along -with a letter explaining that this reflected the accurate ownership of the mineral estate and also noting his belief that Theresa would receive half of Ronald’s share in their pending divorce. Michael also sent a copy of the letter to Theresa’s attorney. In subsequent communications, Anadar-ko told Michael (1) that he would need to transfer 50 percent of the mineral rights to Ronald in order to fix the problem created by the Deed, (2) that Anadarko had sent a letter to Ronald informing him of the Deed’s effect, and (3) that payment of one-half of future royalties would be held in a suspense account until the issue was resolved. In January 2002, Michael began receiving, and depositing in his bank account, royalty payments from the new Anadarko well. That same month, Ronald stopped receiving royalty payments from Chesapeake. Ronald called Chesapeake and was informed of the title problem. In May 2002, Michael testified in Ronald and Theresa’s divorce case regarding the owfiership, and value, of the mineral interests in the Property. Despite the unresolved title problem, Michael testified that Ronald owned half of the mineral rights. On July 5, 2002, the divorce court entered a divorce decree which awarded Theresa a 25 percent interest in the mineral rights in the Property (i.e., half of Ronald’s 50 percent interest). The divorce court did not reform the Deed to reflect a reservation of mineral rights to Ronald. Confusion over ownership of the mineral estate and entitlement to royalty payments persisted for several more years. Theresa advised Ronald in 2003, and again in 2004, that she was not receiving royalty checks from Chesapeake, due to Chesapeake’s concern about the title problem. In April 2004, Michael received his first royalty payment for production from another new Anadarko well, which he deposited in his bank account. In early November 2005, Ronald sent Michael a letter in which Ronald claimed he recently had discovered the problem with the Deed and believed Michael had been receiving royalty payments that should have been paid to him. Michael responded about a week later, noting that Ronald was informed of the Deed problem in October 2001 and that Theresa’s attorney was informed later that year. Michael offered to help investigate any problems with Ronald’s royalty payments if Ronald provided more information, and he agreed to execute a new quit claim deed conveying to Ronald and Theresa in equal shares the one-half mineral interest Ronald had inherited. Ronald did not respond, to this offer. In December 2006, Michael determined that Ronald and Theresa were not receiving royalty payments on production from several wells and came to believe he had received payments belonging to one or both of them. 2. The IRS Tax Liens Ronald did not file tax returns during the years 1997 through 2005, but the IRS determined that he owed, and so assessed against him, federal income tax for those years. The IRS then filed several Notices of Federal Tax Liens in Haskell County, Kansas, thereby effectively encumbering the Property. In April 2005, and again in September 2006, the IRS filed a tax lien for tax years 1997 through 2002. In November 2007, the IRS completed and mailed to Ronald a tax assessment for the years 2003 through 2005. In February 2008, the IRS filed a tax lien for Ronald’s tax liabilities from those years.. All told, the IRS concluded that Ronald owed more than $900,000 in income tax, not including interest or penalties. 3. The Dirt Cheap Mine Trust After receiving notice of the first tax liens, Ronald enlisted the services of James Holden to help Ronald protect his assets. Holden drafted and, on October 6, 2006, executed a “Contractual Trust Agreement” which created a trust called “The Dirt Cheap Mine” (the “Dirt Cheap Mine Trust” or the “Trust”), ostensibly to “provide a retirement vehicle for Ronald Roy Leathers.” The agreement appointed Holden as Trustee for the Dirt Cheap Mine Trust and contemplated that Ronald would convey to the Trust “a certain chose in action” in exchange for 45/100 units of “Participation” in the Trust. That same day, Ronald signed a notarized document entitled “Irrevocable Assignment of Chose(s) in Action” whereby he “convey[ed] all right, title and interests to [the mineral rights he had inherited] and ‘chose(s) in action’ flowing from said ‘mineral rights’ ” to the Trust. The Trust allegedly was created to recover Ronald’s portion of the mineral rights appurtenant to the Property and any royalties mistakenly paid to Michael. But Ronald and Holden both would later concede that the Trust was created to shield Ronald’s assets from the IRS. 4. The Texas Reformation Action On October 20, 2006, an attorney named Joe Alfred Izen, Jr., filed a lawsuit on behalf of Ronald and Holden in Texas state court against Michael; Michael’s wife, Nancy Leathers; Anadarko; Pioneer Natural Resources, USA, Inc.; OXY USA Inc.; and Coastal Petroleum, Inc. The lawsuit sought to reform the Quit Claim Deed, to recover royalty payments that should have been paid to Ronald, and to recover damages from Michael. The Texas case was later dismissed for lack of subject matter jurisdiction because it was deemed an in rem action affecting the Property located in Kansas. Meanwhile, on October 23, 2006, Holden signed a notarized document that appointed and retained Izen “to represent the financial interests of [the] Trust.” In exchange for Izen’s services, the document awarded Izen 45 of the remaining 55 units of Participation in the Trust. On October 27, 2006, Holden executed an “Attorney Consultation and Fee Contract” with Izen on behalf of the Trust, under which the Trust retained Izen for a contingent fee of 45 percent of any amount collected from Michael, Michael’s wife Nancy, and Theresa. Ronald was not a party to either agreement. 5. The Oxy Interpleader Action On February 26, 2007, one month after Michael initiated the present case (which is addressed below), OXY USA Inc. (“Oxy”) filed an interpleader action in the United States District Court for the Southern District of Texas, naming Michael, Nancy, Ronald, Holden, and the IRS as defendants. Oxy was holding approximately $25,000 in suspended royalty payments owed on the disputed one-half mineral interest and sought the assistance of the court in determining who was entitled to the money. Michael and Nancy disclaimed any interest in the royalty payments. That left the IRS, on the one hand, and Ronald and Holden, on the other, with competing claims to the money. The district court concluded, and the attorney for Ronald and Holden seemingly conceded, that Holden was a “fake trustee,” that there was “no substance to the [Dirt Cheap Mine Trust],” and that the Trust was a “fake trust.” Therefore, the district court concluded the IRS had the superior claim to the money. Ronald and Holden appealed, and the United States Court of Appeals for the Fifth Circuit affirmed in an unpublished opinion. See OXY USA Inc. v. Holden, 306 Fed.Appx, 69 (5th Cir. 2009) (per curiam) (unpublished). As relevant here, the Fifth Circuit stated that “[t]he parties conceded [in the district court] that Dirt Cheap Mine Trust was a fake trust, and therefore Holden did not have an interest in the funds-superior to Ronald and the IRS.” Id. at 72. B. Procedural History 1. The Present Case, Generally On January 5, 2007, Michael filed three separate actions in the Kansas state district court located in Haskell County (the “state court”), seeking to quiet title to the disputed one-half mineral interest and the suspended royalties, pursuant to Kansas Statutes Annotated § 60-1002. Michael named as defendants Ronald, Holden, Theresa, and the various energy companies with producing -wells on the Property. The three actions eventually were consolidated. Ronald and Holden initially were represented by local counsel, who filed answers, counterclaims, and crossclaims on their behalf. Then, in March 2007, Izen was admitted pro hoc vice to represent Ronald and Holden in the case. In December 2007, Michael discovered the IRS had filed tax liens against Ronald and moved to amend his petition and to add the United States as a necessary party. His motions were granted, and on June 16, 2008, Michael filed an amended petition, naming the United States as a party potentially claiming an interest in the disputed mineral rights and royalties. The United States filed a notice of removal on July 16, 2008, and the case was removed to the United States District Court for the District of Kansas (the “district court”). Before and after the amended petition was filed and the case removed, the parties submitted various answers, counterclaims, and crossclaims. Because many of these separate actions are relevant to the issues on appeal, we summarize them briefly here. a. Ronald and Holden In February 2007, Ronald and Holden filed an answer to Michael’s original quiet title petitions in which they asserted affirmative defenses and brought counterclaims, crossclaims, and third-party actions. Among the defenses asserted were (1) reformation, asking that the Deed be reformed to reflect the parties’ intention that Ronald would retain the one-half mineral interest he had inherited; and (2) unjust enrichment, stating that Michael paid nothing for the erroneously transferred mineral interest and was unjustly enriched by his retention of the interest and receipt of associated royalty payments. They also asserted four causes of action as either a counterclaim or a crossclaim: • Restitution and/or Recovery of Legal Damages—First, the response asserted a counterclaim against Michael and the energy companies for a decree of restitution ordering that any royalties attributable to the disputed one-half interest (whether disbursed or held in suspense) be paid to Holden (not Ronald), since Ronald allegedly assigned his interest to the Trust. • Breach of Fiduciary Duty and Imposition of Constructive Trust—Second, the response asserted a counterclaim against Michael, alleging Michael owed Ronald a fiduciary duty under Kansas law and breached that duty in various ways. • Decree for Complete Accounting— Third, the response asked for a decree directing all other parties, except Theresa, to prepare and file with the district court a complete accounting of all payments made, due, or received, which are attributable to the disputed one-half interest. • Declaratory Judgment or Equitable Decree—Finally, as a crossclaim against Theresa, the response asserted Ronald and Holden are entitled to a decree finding that, to the extent they successfully recover the mineral interest, royalty money, or other damages, they should recover those damages free of any claim of Theresa. Ronald and Holden asserted that, due to the Deed, Ronald did not own the mineral interest at the time of Theresa and Ronald’s divorce. They therefore claimed the divorce court lacked authority to award Theresa a share of the mineral interest in the decree because it was not marital property- Ronald and Holden summarized their requested relief in a list of 15 items, which included reformation of the Deed and an order declaring that the disputed one-half interest and related royalties are now owned by Holden, as Ronald’s assignee. Neither Ronald nor Holden filed a response to Michael’s amended petition. b. Theresa In February 2007, Theresa filed answers to Michael’s original petitions, requesting that the court enter a decree quieting title, assigning her a 25 percent interest in the mineral rights, and ordering the energy companies to pay her the corresponding portion of the suspended royalties. On July 30, 2008, Theresa filed in the state court an “Answer/Cross-elaim/Counter-claim” to Michael’s amended petition. Because the United States had removed the case already, this pleading was not transferred to the district court. Theresa then filed a notice of her pleading in the district court, with the pleading attached. Theresa organized her counterclaim against Ronald and Holden, and crossclaim against Michael, under the same heading, generally asserting that (1) she is entitled to a judgment declaring her the owner of 25 percent of the mineral rights appurtenant to the Property, contrary to Michael’s claim; (2) Ronald is barred by res judicata from asserting claims against her that conflict with the divorce decree; (3) Ronald and Holden’s claims against her should be disallowed because they are meritless; (4) she should be awarded fees associated with defending against Ronald and Holden’s claims; (5) the court should order an accounting, similar to that requested by Ronald and Holden; and (6) the court should order that her interest in the mineral estate and royalties is free of any claim by the IRS. c. The United States After removing the case to federal court, the United States filed its first answer to Michael’s amended petition on August 18, 2008. On June 21, 2010, the government filed an amended answer in which it asserted a single crossclaim against Ronald. Specifically, the government brought a civil action under 26 U.S.C. § 7401 to reduce the outstanding tax assessments against Ronald to judgment. The government alleged that, as of May 1, 2010, Ronald owed approximately $1.4 million in income tax for the years 1997 through 2005, including interest, and it asked for a judgment against Ronald in that amount, plus future interest. Ronald and Holden answered the United States’ crossclaim on July 9, 2010, asserting various affirmative defenses. 2. Bifurcation, and First Round of Dispositive Motions in the Quiet Title Phase In November 2008, the district court granted the parties’ joint motion for separate trials, ruling that the case should be bifurcated. The court determined that the quiet title issues, including Ronald and Holden’s, and Theresa’s, respective counterclaims and crossclaims, should be addressed in the first phase of the litigation. All other issues, including the accounting actions and tax matters, would be addressed in a second phase thereafter. Between March and April of 2009, Theresa, Michael, and Ronald and Holden each filed motions for summary judgment regarding the first-phase issues and claims. On May 13, 2010, after the motions were fully briefed and heard, the district court issued a comprehensive order granting Theresa’s motion, and granting in part and denying in part both Michael’s, and Ronald and Holden’s, motions (“May 2010 Order”). We now summarize the parties’ arguments, and the district court’s findings, with respect to the issues relevant to the present appeals. a. Reformation and Quiet Title Theresa moved for summary judgment, asking the court to grant Michael’s request for quiet title. Specifically, Theresa argued the court should (1) reform the Deed to reflect the parties’ original intention that Ronald would reserve his one-half mineral interest, and (2) enforce the divorce decree by awarding her half of Ronald’s 50 percent mineral interest. Michael did not oppose Theresa’s requested relief. Although Ronald and Holden also sought reformation of the Deed to reflect the parties’ intent that Ronald retain his 50 percent interest in the mineral estate, they opposed on several grounds Theresa’s claim to a one-quarter portion of the mineral rights. The district court determined reformation was appropriate under Kansas law due to mutual mistake because both Michael and Ronald intended that Ronald would retain his one-half interest in the mineral estate when he conveyed his one-half interest in the surface estate to Michael by the Deed. The district court further concluded that the reformation related back to the date the Deed was executed—May 11, 1998—and took effect from that date forward, binding all but good faith purchasers in any subsequent transactions. The district court then quieted title to the mineral rights in the following shares: 50 percent to Michael, 25 percent to Ronald, and 25 percent to Theresa in accordance with the divorce decree. In doing so, the court rejected Ronald and Holden’s various arguments opposing Theresa’s claim. First, it disposed of their argument that the divorce court lacked authority to award Theresa an interest in the mineral rights because, per the mistake in the Deed, Ronald did not own the rights at the time of the divorce. The district court found, to the contrary, that Ronald owned the mineral rights at the time of the divorce because the reformation related back to the date the Deed was signed, which occurred before entry of the divorce decree. Next, the court rebuffed several of Ronald and Holden’s arguments premised on the notion that Theresa was attempting to reopen, modify, and/or set aside the divorce decree—e.g., arguments invoking a statute of limitations bar, the domestic relations exception to federal jurisdiction, and other jurisdictional limitations—because the court concluded Theresa was not attempting to do any of those things. Rather, Theresa was asking the court to enforce the divorce decree as written. And the district court determined the divorce court’s judgment should be given preclu-sive effect because Ronald and Theresa had a fair opportunity to litigate their claims in the divorce proceeding. Thus, the district court concluded that, to the extent Ronald and Holden were attempting to relitigate the divorce court’s award of half Ronald’s mineral interest to Theresa, their claim was barred by res judicata and full-faith-and-credit principles. b. Unjust Enrichment / Constructive Trust Michael, and Ronald and Holden, filed cross motions for summary judgment on Ronald and Holden’s claim for unjust enrichment and their request that the court impose a constructive trust on royalties which belonged to Ronald but were paid ⅜0 Michael. Michael argued the unjust enrichment claim failed as a matter of law because Ronald did not confer a benefit on him, the claim was barred by the doctrine of unclean hands, the claim was barred by the statute of limitations, and Ronald could not recover on the claim in any event because he had transferred his interest to the Dirt Cheap Mine Trust. The district court determined that summary judgment was not warranted on the unjust enrichment claim because a reasonable jury could find (1) a benefit was conferred on Michael, (2) Michael had an appreciation or knowledge of that benefit beginning in December 2006, and (3) Michael retained or accepted that benefit when he deposited certain disputed royalty payments in his bank account. Turning to Michael’s unclean hands defense, the court concluded a jury should decide, based on the evidence, whether Ronald acted with unclean hands. Next, the court determined the unjust enrichment claim was not barred by Kansas’s three-year statute of limitations because the limitations period did not begin to run until Michael knew of the misapplied royalty payments, which a jury could find to be December 2006— within the limitations period. 3. Culmination of the Quiet-Title Phase Following the May 2010 Order, the parties participated in a pretrial conference, and on July 12, 2011, the district court issued a pretrial order which, among other things, defined the scope of the remaining factual and legal issues in the quiet title stage. Around this time, the parties submitted various additional dispositive motions. Theresa moved for summary judgment on her remaining claim of unjust enrichment against Michael. In late July 2011, Ronald and Holden filed a “First Amended Counter-claim and Cross-claim” in which they reasserted many of their prior claims addressed in the May 2010 Order and pleaded counterclaims for conversion and fraud-by-silence against Michael. They then moved for summary judgment on the conversion and fraud-by-silence claims. Michael filed a motion to dismiss or for summary judgment on those counterclaims. On May 29, 2012, the district court issued an order addressing these and other motions (“May 2012 Order”). It denied Theresa’s motion for summary judgment against Michael on her unjust enrichment claim “essentially for the same reasons as set out in the [May 2010 Order]” with respect to Ronald and Holden’s unjust enrichment claim. The district court also denied Michael’s motion to dismiss the conversion and fraud-by-silence counterclaims; however, it granted Michael’s alternative request for summary judgment as to both. Thus, after the May 2012 Order, there remained two unresolved issues in the first phase of the litigation: (1) “Do the royalty-payments received by Michael result in a constructive trust for Ronald and Theresa?” and (2) “Was Michael unjustly enriched?” After the energy companies had submitted their royalty accountings, Michael filed another motion for summary judgment requesting that the district court limit his monetary exposure on the unjust enrichment claims. On August 28, 2013, the district court granted Michael’s motion (“August 2013 Order”). The court found that the amount of money received by Michael which should have been paid to Ronald and Theresa was $32,665.96 and that this figure represented Michael’s maximum liability on the unjust enrichment claims. Because Ronald and Theresa each were entitled to half of that amount, Michael’s maximum liability on each claim was $16,332.98. Theresa died at some point during the litigation, and the representative of her estate accepted an offer of judgment from Michael for $16,332.98. The district court entered judgment against Michael for this amount in December 2013. Although Ronald and Holden’s parallel claim initially was set for an October 2014 bench trial, along with tax issues from the second stage of the case, the bench trial was postponed when the court learned that Ronald had filed for bankruptcy in Colorado. Thereafter, Holden accepted an offer of judgment from Michael for $16,332.98, and on September 2, 2015, the district court approved a stipulated order of partial judgment resolving the unjust enrichment claim in favor of Holden and against Michael. The stipulated order declared that Holden held the unjust enrichment claim by virtue of Ronald’s assignment of his choses in action to the Trust in 2006. The district court later noted that Ronald “has waived or is estopped from challenging Holden’s settlement of the unjust enrichment claim with [Michael], based on Ronald’s representation that Holden was his assignee on this claim.” These judgments disposed of the unjust enrichment claims and brought the quiet title phase of the bifurcated proceedings to an end. 4. The Tax’Phase As noted above, after the United States removed this case to federal court, it filed a crossclaim against Ronald seeking to reduce Ronald’s outstanding tax debt to judgment. Ronald and Holden filed an answer to the crossclaim in which they raised various affirmative defenses and sought attorney fees “they incurred in proving ownership of the mineral interests in question against which the United States purports to assert a lien.” On November 28, 2012, the United States moved for summary judgment on its crosselaim and for dismissal of Ronald and Holden’s claim for attorney fees. The government submitted exhibits showing that Ronald failed to pay income taxes from 1997 to 2005 and that, as of September 21, 2012, he owed the IRS $1,561,117.06. Ronald and Holden, through Izen, opposed the motion on various grounds. They asserted that, even if the IRS had a valid claim to royalty payments from Ronald’s mineral interest, Izen’s contingent fee agreement with the Trust gave him a superpriority lien on any recovery by the Trust over and above any tax lien, pursuant to 26 U.S.C. § 6323(b)(8). On May 3, 2013, the district court issued an order granting in part and denying in part the United States’ motion (“May 2013 Order”). Based largely on deficiencies in Ronald and Holden’s response, the district court concluded that the government’s version of the facts was uncontroverted. The court then granted summary judgment for the United States on Ronald’s tax debt for the years 1997 and 1999 through 2005, and reduced the assessments from those years to judgment. But it decided that a factual dispute precluded summary judgment as to tax year 1998. The district court also concluded that all royalties found owing to Ronald would be subject to the IRS tax liens, but it did not finally determine the priority of those liens vis-a-vis other claims. The court rejected the government’s contention that the “fake trust” findings made in the Oxy interpleader action collaterally estopped Ronald and Holden from arguing Ronald’s assignment to the Trust gave the Trust a valid claim to the royalties. Specifically, the court concluded the finding of the Texas federal court—that Ronald and Holden had conceded the Trust was a “sham”—did not represent a final adjudication on the merits of the Trust’s validity because the validity of the Trust was not actually litigated in that case. The court reserved the issue for trial, “expressing] no opinion ... on the validity of the trust or the purported assignment by Ronald.” And the district court granted the government’s summary judgment motion with respect to Izen’s claim for attorney fees under 26 U.S.C. § 6323(b)(8), but it did so without prejudice to reassertion of the claim at a later time. Next, in December 2013, the United ■ States filed a motion for summary judgment seeking to foreclose its tax liens and establish their priority. Holden (apparently without Ronald) filed a cross motion for partial summary judgment. On February 27, 2014, the district court issued an order granting in part and denying in part the United States’ motion and denying Holden’s (“February 2014 Order”). The court concluded that the tax lien for the years 1997 and 1999 through 2002, which the IRS first filed in April 2005, had first priority to the royalties from Ronald’s share of the mineral interest, and that Holden had conceded as much. But the court determined there was a triable issue of fact as to the priority of the lien for the years 2003 through 2005. Because Ronald purportedly transferred his mineral interest and choses in action to the Trust in October 2006, and the IRS did not file a lien on the 2003-2005 taxes until 2008, the court explained that the lien for those years would not be valid against the Trust “unless [the United States] establishes that Ronald fraudulently transferred his interest to the trust.” Thus, the parties prepared and submitted briefing for a bench trial on the remaining issues in the case: (1) the United States’ claim against Ronald for unpaid taxes from 1998; (2) the validity of the Dirt Cheap Mine Trust and/or Ronald’s October 2006 transfer to it; and (3) Izen’s renewed request for attorney’s fees pursuant to 26 U.S.C. § 6323(b)(8). The district court held a bench trial on September 17, 2015 and issued its rulings in a written order on September 25, 2015 (“September 2015 Order”). First, the court held that the United States was entitled to judgment on its claim against Ronald for $192,205.24 in unpaid taxes from 1998. Second, the district court found that “Ronald’s transfer of the chose-in-actionv involving his mineral rights to the trust (as well as the transfer of the mineral rights, to the extent he purported to transfer them) constituted a fraudulent transfer with respect to his tax debt to the IRS.” The court reasoned that the “circumstances surrounding the transfer and the deposition testimony of Ronald and Holden show that Ronald’s intent in making the transfer was to hinder the IRS from collecting Ronald’s tax debt.” Indeed, the district court found that “the whole purpose of the trust was to attempt to remove from the reach of the IRS the mineral interest and any royalties to which Ronald was or would be entitled.” The court noted that Holden himself had acknowledged that, “if Ronald’s purpose had been merely to sue Michael to obtain a share of the mineral rights and royalties, he could have simply retained Izen to pursue the claim on a contingency fee basis and wouldn’t have needed any sort of trust or transfer of property.” As a result, the district court declared the transfer to be “null and void” and held “the federal tax liens are senior to any interest in the property claimed by Ronald Leathers, the Dirt Cheap Mine Trust, or James Holden.” The court accordingly held that the government was entitled to a final judgment against Ronald in the amount of $1,545,779.36, which represented Ronald’s current, combined tax obligations for the years 1997 through 2005. Finally, the district court granted Izen’s request for attorney fees, in part. Izen requested a total of $164,178.16 in fees and costs, but the court awarded him a total of $39,689.88. Pursuant to 26 U.S.C. § 6323(b)(8), the court held Izen had a lien in that amount which was superior to the federal tax liens. 5. Post-Judgment The September 2015 Order disposed of all remaining issues in the case. On the same day the order was issued, the court entered a judgment which briefly summarized its various rulings throughout the bifurcated proceedings. On October 23, 2015, Holden and Izen together filed a “motion for new trial and motion for amended and/or additional findings,” and Izen separately filed a “motion for rehearing or new trial and motion for amended and/or additional findings.” The district court denied both motions on November 19, 2015. Ronald filed a timely appeal from the district court’s judgment, and Holden and Izen jointly filed a separate appeal. Although the three acted together in the district court, with Izen representing both Ronald and Holden in his capacity as Trustee, their interests are not aligned on appeal. Theresa’s appellate interests are being pursued by her successors, Ronda R. Olson and Rustin R. Leathers, but for the sake of clarity, we continue to refer to the claims as Theresa’s. We have jurisdiction under 28 U.S.C. § 1291. In the interest of clarity, we address the substantive aspects of the two appeals separately, beginning with Ronald’s appeal before turning to Holden and Izen’s. For the reasons set forth below, we affirm the district court’s judgment on all grounds. III. CASE NO. 15-3264, RONALD’S APPEAL Ronald lists ten issues in the statement of issues section of his brief, but the argument section does not address each issue. We have identified the issues Ronald actually briefs as: (1) the state court lacked ■subject matter jurisdiction over the initial quiet title actions because Michael did not have standing, and therefore the state court’s orders are void; (2) the district court also lacked subject matter jurisdiction; (3) Izen’s simultaneous representation of Ronald and Holden created a conflict of interest; (4) the Dirt Cheap Mine Trust is a sham trust; (5) Ronald’s mineral interest and royalties were taken in violation of due process; and (6) the district court erred in limiting Michael’s potential liability for unjust enrichment damages to misapplied payments received in December 2006 or later. We address and reject these arguments in turn. A. The State Court’s Jurisdiction Ronald first contends that Michael lacked standing to bring the underlying quiet title actions in Kansas state court and that the state court therefore lacked subject matter jurisdiction. Specifically, Ronald argues Michael had no legitimate claim to the one-half mineral interest and therefore could not bring an action under the Kansas quiet title statute, Kansas Statutes Annotated § 60-1002. According to Ronald, because the state court did not have jurisdiction, its “orders ... allowing Attorney Izen to practice, Michael to amend his petition, and the United States to be added as an indispensable party are void.” We disagree. “[Standing is a jurisdictional issue in Kansas.” Mid-Continent Specialists, Inc. v. Capital Homes, L.C., 279 Kan. 178, 106 P.3d 483, 488 (2005). “The issue of whether a party has standing in a judicial action ... presents a question of law.” Sierra Club v. Moser, 298 Kan. 22, 310 P.3d 360, 367 (2013). Like other jurisdictional issues, we review questions of standing de' novo. Meyer v. Christie, 634 F.3d 1152, 1156 (10th Cir. 2011); accord Mid-Continent Specialists, 106 P.3d at 488. Under Kansas law, “[sjtanding to sue means that a party has a sufficient stake in an otherwise justiciable controversy to obtain judicial resolution of that controversy.” Dutoit v. Bd. of Cty. Comm’rs, 233 Kan. 995, 667 P.2d 879, 887 (1983). A plaintiff must satisfy both the relevant statutory standing requirements, if any, as well as traditional or common-law standing requirements. See Moser, 310 P.3d at 367-69. “[T]o demonstrate common-law or traditional standing, a person suing individually must show a cognizable injury and establish a causal connection between the injury and the challenged conduct.” Id. at 369. Kansas’s quiet title statute creates a “[r]ight of action” that “may be brought by any person claiming title or interest in personal or real property, including ... mineral or royalty interests, against any person who claims an estate or interest therein adverse to him or her, for the purpose of determining such adverse claim.” Kan. Stat. Ann. § ’60-1002(a). “Thus, ih order to properly bring a quiet title action pursuant to the statute, a person must claim ‘title or interest’ in the real property.” Dubowy v. Baier, 856 F.Supp. 1491, 1497 (D. Kan. 1994) (discussing Kan. Stat. Ann. § 60-1002). The person against whom the action is brought must “claim[ ] an estate or interest therein which is adverse to that of the owner” who filed the action, and “[t]he action may be brought for the purpose of determining such adverse claims.” LaBarge v. City of Concordia, 23 Kan.App.2d 8, 927 P.2d 487, 494 (1996) (internal quotation marks omitted). “Ordinarily a quiet title action is brought to remove a cloud from the title.... ” Ford v. Sewell, 188 Kan. 767, 366 P.2d 285, 289 (1961). Here, Michael had standing under § 60-1002. In his original petitions filed January 5, 2007, Michael claimed ownership of the disputed one-half mineral interest by virtue of the Quit Claim Deed and asked that title to that interest be quieted in him. He also detailed the ways in which the “clouded title” to this interest was impeding royalty payments, and he identified “at least three conflicting claims to the undivided [one-half] interest”: his own claim, Ronald’s (and the Trust’s) claim, and Theresa’s claim. Thus, we have here “a factual situation which ... meet[s] the definition of a quiet title action: two [or more] parties asserting adverse interests with regard to certain mineral rights.” Ferrell v. Ferrell, 11 Kan.App.2d 228, 719 P.2d 1, 4 (1986). Ronald seeks to confute Michael’s standing by arguing, essentially, that Michael either (1) could not “claim” the one-half mineral interest because the divorce court had already distributed that interest and Michael had testified in the divorce case that Ronald owned the interest; or (2) did not “claim” the interest because he eventually changed his position and conceded to the interest being allocated to Ronald and Theresa. Ronald also seems to argue that Michael could not or did not claim ownership of the one-half mineral interest because the interest was never transferred to Michael in the first place. But these arguments ignore several critical and undisputed facts. First, the Deed did transfer Ronald’s one-half mineral interest in the Property to Michael, as the district court concluded. Although the district court further found that this transfer was unintended, the Deed nonetheless made Michael the legal owner of 100 percent of the mineral estate in the Property. And because the Deed had not yet been reformed at the time of the divorce decree, the divorce court’s allocation of one-half of the mineral estate between Ronald and Theresa further clouded title. Michael’s testimony in the divorce case reflects that he knew there was a title problem but believed it eventually would be resolved in Ronald’s favor. By the time Michael filed his quiet title action, he had revised his position to claim ownership of the entire mineral estate based on the Deed. In short, Michael had a valid claim to the disputed mineral interest by virtue of the Deed, and Ronald’s contention to the contrary is meritless. Nor does Michael’s eventual desertion of his claim to the interest deprive him of standing, which is measured as of the time a plaintiff files suit. See U.S. Bank Nat’l Ass’n v. McConnell, 48 Kan.App.2d 892, 305 P.3d 1, 6-8 (2013); accord Davis v. Fed. Election Comm’n, 554 U.S. 724, 734, 128 S.Ct. 2759, 171 L.Ed.2d 737 (2008) (“[T]he standing inquiry remains focused on whether the party invoking jurisdiction had the requisite stake in the outcome when the suit was filed.” (emphasis added)); Brown v. Buhman, 822 F.3d 1151, 1164 (10th Cir. 2016). Although Ronald alleges that Michael abandoned his pursuit of the half interest in the mineral estate “[o]ne week after the filing of his amended petition,” Ronald fails to mention that the amended petition was itself filed more than a year after the initial quiet title petitions. Ronald points to no authority suggesting that Michael’s later change of position can override the standing conferred by his initial pleadings asserting his legitimate claim to ownership under the Deed. Ronald also ignores the fact that Michael’s change in position occurred after Ronald himself had asserted various counterclaims and crossclaims and had asked the state court to reform the Deed and quiet title to the disputed interest. In Kansas, “[a]s a general rule a ... counterclaim or cross-claim has the nature, characteristics and effect of an independent action or suit by one party against another. Accordingly, ... a demand pleaded by way of a ... counterclaim or cross-claim is regarded as an affirmative action.... ” Mynatt v. Collis, 274 Kan. 850, 57 P.3d 513, 525 (2002) (internal quotation marks omitted). Ronald does not dispute the state court’s jurisdiction over these independent claims seeking the same relief as Michael’s initial actions. Thus, even if we were convinced that Michael’s decision mid-litigation to relinquish his claim to one-half of the mineral estate affected the state court’s jurisdiction over Michael’s § 60-1002 claims, we still would conclude the state court had jurisdiction over the case by virtue of the counterclaims and crossclaims. Cf. Caplinger v. Carter, 9 Kan.App.2d 287, 676 P.2d 1300, 1304 (1984) (stating that a counterclaim can remain pending for independent adjudication even after the plaintiffs claims have been dismissed). We therefore reject Ronald’s argument that the state court lacked subject matter jurisdiction and his corresponding claim that the state court’s orders are void. B. The District Court’s Jurisdiction Ronald also contends the federal district court lacked subject matter jurisdiction and that its orders, too, are void. Reviewing the issue de novo, see Knight v. Mooring Capital Fund, LLC, 749 F.3d 1180, 1183 (10th Cir. 2014), we reject Ronald’s arguments and conclude the district court had jurisdiction. Ronald first argues that the district court lacked jurisdiction because the state court lacked jurisdiction, due to Michael’s alleged lack of standing. Because we have concluded that the state court did have jurisdiction, we reject this contention. Next, Ronald seems to assert that the district court did not have federal question jurisdiction over the Kansas quiet title claims. But the district court’s assertion of subject matter jurisdiction did not rest on federal question jurisdiction. When Michael learned of the federal tax liens on Ronald’s property and added the United States as a necessary party to the state-court litigation, he did so under the authority of 28 U.S.C. § 2410, which waives the United States’ sovereign immunity with respect to state-court quiet title actions concerning property over which the government has asserted a lien. See 28 U.S.C. § 2410(a); Guthrie v. Sawyer, 970 F.2d 733, 735 (10th Cir. 1992). “As a trade off for the waiver of sovereign immunity, [28 U.S.C. § 1444] permits the government to remove to federal court any such case initiated in state court.” Hussain v. Boston Old Colony Ins. Co., 311 F.3d 623, 629 (5th Cir. 2002). Section 1444 gives the United States “a substantive right to remove, independent of any other jurisdictional limitations.” Id. (internal quotation marks omitted); see also Hudson Sav. Bank v. Austin, 479 F.3d 102, 105 (1st Cir. 2007) (“28 U.S.C. § 1444 ... confers upon the federal government an absolute right to remove to federal court [quiet title] actions in which it is named as a defendant....”). In other words, at the time this case was removed, the district court’s jurisdiction was premised on §§ 2410 and 1444, and not, as Ronald claims, on 28 U.S.C. § 1331. See City of Joliet v. New West, L.P., 562 F.3d 830, 833 (7th Cir. 2009) (“[T]he presence of the national government as a party with a security interest in the real estate supplies jurisdiction.” (citing 28 U.S.C. §§ 1444, 2410)); Hussain, 311 F.3d at 629 (“Once the applicability of § 2410(a) is established, federal subject matter jurisdiction is present on the basis of § 1444.”); see also Quality Loan Serv. Corp. v. 24702 Pallas Way, 635 F.3d 1128, 1131-32 (9th Cir. 2011); 14C Charles Alan Wright et al., Federal Practice and Procedure § 3728, at 307 (4th ed. 2009). We therefore reject this argument, too. Finally, Ronald spends two or three sentences articulating his belief that the district court was precluded by “the doctrines of res judicata and Rooker-Feldman” from reforming the Quit Claim Deed because the prior divorce decree already established that Ronald owned the one-half mineral interest. While it is not apparent how these arguments relate to the district court’s subject matter jurisdiction, we need not dwell on that question because both points can be rejected on the merits. The res judicata contention is inadequately briefed and therefore waived, as Ronald cites no legal authority and offers no explanation beyond his bare as-, sertion that res judicata precludes reformation in this case. See United States v. Pursley, 577 F.3d 1204, 1228 (10th Cir. 2009) (rejecting an argument a party “mentioned], but d[id] not justify,” and did “not cite a single case to support,” under “the principle that arguments inadequately briefed in the opening brief are waived” (alteration and internal quotation marks omitted)). This contention is also meritless, as Michael was not a party to, and neither quiet title nor reformation was litigated in, the divorce case. See Lenox MacLaren Surgical Corp. v. Medtronic, Inc., 847 F.3d 1221, 1239 (10th Cir. 2017) (stating that two of the requisite elements of res judicata are “identity of parties or privies in the two suits” and “identity of the cause of action in both suits” (internal quotation marks omitted)). The argument concerning Rooker-Feldman—a doctrine Ronald recognizes “is not a jurisdictional matter”— fails for equally straightforward reasons. “Rooker-Feldman precludes federal district courts from effectively exercising appellate jurisdiction over claims actually decided by a state court and claims inextricably intertwined with a prior state-court judgment.” Mo’s Express, LLC v. Sopkin, 441 F.3d 1229, 1233 (10th Cir. 2006) (internal quotation marks omitted). The doctrine “is confined to ... cases brought by state-court losers complaining of injuries caused by state-court judgments rendered before the district court proceedings commenced and inviting district court review and rejection of those judgments.” Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280, 284, 125 S.Ct. 1517, 161 L.Ed.2d 454 (2005). Here, the quiet title and reformation claims were not addressed by the state divorce court, and the district court did not review or reject the divorce court’s judgment. Furthermore, as a non-party to the state divorce proceedings, Michael cannot be deemed a state court “loser.” The Rooker-Feldman doctrine therefore does not apply. Thus, we conclude the district court had jurisdiction and reject Ronald’s various arguments to the contrary. C. Conflict of Interest Ronald’s next complaint is that Izen had an undisclosed conflict of interest and should not have been representing Ronald in the district court proceedings. Ronald’s treatment of this claim in his brief begins with a page-long quote of paragraphs (a) and (b) of ABA Model Rule of Professional Conduct 1.7. Paragraph (a) forbids representation that involves a concurrent conflict of interest, and paragraph (b) lists circumstances under which the representation may proceed despite a concurrent conflict. See Model Rules of Prof 1 Conduct r. 1.7(a)-(b) (Am. Bar Ass’n 2014). Immediately following this excerpt, Ronald contends that Izen “violated every subsection.” We need not decipher the particulars of Ronald’s argument or decide whether a conflict existed because, regardless, this issue is inadequately briefed and is not properly before us. Aside from the quoted ABA Rule, Ronald cites to no legal authority, and his discussion consists largely of tangential references to other substantive areas of the case. Cf. Birch v. Polaris Indus., Inc., 812 F.3d 1238, 1249 (10th Cir. 2015) (declining to consider argument as “unsupported and inadequately briefed” where the allegations offered in support of the argument were “in most cases vague, confusing, conclusory, and unsupported by record evidence”). Plus, this argument is forfeited because Ronald did not raise it in the district court. See Hall v. U.S. Dep’t of Labor, 476 F.3d 847, 861 (10th Cir. 2007). Although it may have been difficult for him to do so, since Izen was his attorney at that time, Ronald does not provide any authority outlining an exception to the application of normal forfeiture principles in a situation such as this or even offer a theoretical rationale for such an exception. We therefore decline to consider the merits of this issue. See Namoko v. Cognisa Sec., Inc., 264 Fed.Appx. 753, 755 (10th Cir. 2008) (unpublished) (declining to consider for the first time on appeal plaintiffs argument that his counsel in the district court violated the Colorado Rules of Professional Conduct). D. Limitation on Unjust Enrichment Liability Finally, Ronald argues the district court erred in concluding that Michael’s liability for unjust enrichment should be limited to misapplied payments he received in or after December 2006, which the district court found to be the point at which Michael realized he was being overpaid. The district court based this determination on the second element of an unjust enrichment claim under Kansas law, which requires that “the defendant appreciated and has knowledge of the benefit” conferred on him by the plaintiff. See Univ. of Kan. Hosp. Auth. v. Bd. of Comm’rs, 299 Kan. 942, 327 P.3d 430, 441 (2014). But according to Ronald, knowledge is a prerequisite for an- unjust enrichment claim to accrue and for the statute of limitations to commence, but it is not a limit on restitution of amounts received before the defendant gained that knowledge. Ronald maintains the district court erred in giving the requirement the latter effect. While this argument, if properly-raised, might present an interesting issue, we decline to consider it on the merits. Like so many of the arguments Ronald raises on appeal, this argument is not adequately briefed. Ronald simply states that the second element of unjust enrichment “does not create a bar of recovery for a benefit conferred before the Defendant knew of the benefit” without elaborating further or citing any legal authority in support. Thus, we are free to end our inquiry by deeming this contention waived. See Phillips v. Calhoun, 956 F.2d 949, 953 (10th Cir. 1992) (declining to consider argument that was not “minimally supported by legal argument or authority”). But the argument also fails because Ronald cannot raise it. Ronald is not the real party in interest for the unjust enrichment claim because he assigned his choses in action to Holden, who settled the claim through a stipulated judgment. See Wade v. EMCASCO Ins. Co., 483 F.3d 657, 674-75 (10th Cir. 2007) (“Kansas law requires that every legal action be prosecuted by the real party in interest.... Where the injured party assigns all of his rights to a third party, the assignee becomes the real party in interest and the assignor can no longer pursue a claim on his own behalf.”). Ronald does not contest that a claim for unjust enrichment is an assignable chose in action under Kansas law. See Bolz v. State Farm Mut. Auto. Ins. Co., 274 Kan. 420, 52 P.3d 898, 901 (2002) (“It has long been recognized in Kansas that all choses in action, except torts, are assignable.”); Regal Ware, Inc. v. Vita Craft Corp., 653 F.Supp.2d 1146, 1151 (D. Kan. 2006) (“[Ujnjust enrichment is a quasi-contractual remedy, not a tort.”). Nor does he address, let alone offer a reason for us to reject, the district court’s conclusion that he “has waived or is estopped from challenging Holden’s settlement of the unjust enrichment claim with [Michael], based on [his] representation that Holden was his assignee on this claim.” Because this argument is inadequately briefed, and because the unjust enrichment claim has been assigned and settled, we reject Ronald’s challenge to the district court’s statute of limitations ruling with respect to that claim. * * * For the reasons set forth above, we conclude Ronald has raised no valid challenge to the district court’s rulings. We therefore affirm the district court’s judgment on all grounds raised in Case No. 15-3264. Having done so, we now turn to the substantive issues raised in Case No. 15-3280. IV. CASE NO. 15-3280, HOLDEN AND IZEN’S APPEAL In their separate appeal, Holden and Izen present eight issues for our consideration. Distilled and grouped together where sensible, their arguments are as follows: (1) the district court erred in allocating to Theresa 25 percent of the mineral rights appurtenant to the Property; (2) the district court erred in concluding Ronald and Holden’s conversion counterclaim was barred by the statute of limitations; (3) the district court erred, both procedurally and substantively, in determining that Ronald’s transfer of his choses in action to the Dirt Cheap Mine Trust was fraudulent with respect to Ronald’s tax debt to the IRS; and (4) the district court abused its discretion in resolving Izen’s request for attorney fees. Addressing these arguments in turn, we reject them all and affirm the district court’s decision in full. A. Arguments Concerning Theresa’s Interest Holden and Izen begin with several arguments for why the district court erred in awarding Theresa half of Ronald’s one-half mineral interest based on the state divorce decree. The premise on which all these arguments rest is Holden and Izen’s belief that the divorce court’s distribution of the mineral interest between Ronald and Theresa was void because, due to the error in the Quit Claim Deed, Ronald did not then own the interest. According to Holden and Izen, the district court therefore effectively reopened and corrected or modified the divorce decree when it allocated half of Ronald’s interest to Theresa. This, they argue, was impermissible both under the applicable statute of limitations and because of a jurisdictional bar. But the key assumption underlying Holden and Izen’s arguments—i.e., that the divorce court’s division of the mineral interest is void because Ronald did not own the interest at the time of the divorce—is flawed. Holden and Izen fail to acknowledge the district court’s conclusion that, because the reformation of the Deed relates back to the Deed’s execution, Ronald did own the interest during the divorce and the divorce court therefore had authority to distribute half of that interest to Theresa. As we now explain, the district court’s conclusion is correct, and as a result, Holden and Izen’s arguments necessarily fail. We review the district court’s legal conclusions de novo. Smalley & Co. v. Emerson & Cuming, Inc., 13 F.3d 366, 367 (10th Cir. 1993) (“When considering a grant of summary judgment we review the district court’s conclusions of law de novo.... ”). Under Kansas law, “[r]eformation is an equitable remedy available to correct mutual mistakes of fact.” Conner v. Koch Oil Co., 245 Kan. 250, 777 P.2d 821, 825 (1989). “When a mutual mistake is made in describing property in a deed and the instrument does not convey the property intended, the deed may be reformed to conform to the parties’ original intentions.” Unified Gov’t of Wyandotte Cty./Kan. City v. Trans World Transp. Servs., L.L.C., 43 Kan.App.2d 487, 227 P.3d 992, 997 (2010). “This is because when property is included in a deed by mutual mistake and the parties never intended such property to be conveyed, the grantor is under no obligation to convey such property, and the grantee has no right to retain such property.” Id. Here, the district court concluded that neither Michael nor Ronald intended for Ronald to convey his one-half mineral interest when he executed the Quit Claim Deed, and that the failure of the Deed to reserve Ronald’s mineral interest was a mutual mistake. The court accordingly reformed the Deed such that Ronald’s one-half mineral interest was reserved to him. Holden and Izen do not contend reformation for mutual mistake was improper. But their arguments neglect one of that doctrine’s principal consequences. In Kansas, as elsewhere, “reformation of an instrument relates back, and takes effect from, the time of its original execution, and binds all entities except innocent purchasers for value.” Conner, 777 P.2d at 825; see also 66 Am. Jur. 2d Reformation of Instruments § 9 (“The reformation of an instrument relates back to the time the instrument was originally executed and simply corrects the document’s language to read as the instrument should have read all along. A reformed instrument takes effect from the time of its original execution and binds all entities except innocent purchasers for value.”). The district court therefore concluded that reformation of the Deed was effective as of its execution on May 11, 1998. As a result, the court further determined that Ronald owned the one-half mineral interest at the time of the divorce proceeding in 2001 and 2002, and the divorce court properly distributed it as part of the marital estate. Although we have found no Kansas case dealing directly with a court’s prior disposition of property belonging to a party whose ownership of the property was only later validated upon reformation, the district court’s ruling here follows naturally from the relation-back rule as stated and applied in Conner. See 777 P.2d at 823-26. And that ruling is supported by this court’s and other courts’ decisions applying Colorado and Oklahoma law, which embrace the same relation-back principle as Kansas law. See, e.g., Chapman v. Denman, 190 Fed.Appx. 640, 644 (10th Cir. 2006) (unpublished) (applying Colorado law) (“[PJlaintiff argues that Pitkin County never owned the [land] until 2004 when