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A Lesson on How Not to Recover an NPRI in Texas

It seems to be fairly well settled that you can’t use trespass-to-try-title to recover a nonpossessory royalty interest in Texas. What if you call the interest a “mineral interest stripped of every attribute except the right...more

Limitations and Standing to Sue Dry Up Landowners’ Claim to Texas Riverbed

State of Texas. V. Reimer et al. studied lawyer-nerdy questions of standing to bring a lawsuit and statutes of limitations as applied to inverse condemnation suits.  Spoiler alert: To the chagrin of the landowners, waiting...more

Another Louisiana Post-production Cost Case … and More

Dow Construction, LLC v. BPX Operating Company resolved a bundle of issues arising out of a drilling unit established by the Louisiana Commissioner of Conservation: who has the right to a drilling cost report, the operator’s...more

It’s Been Decided, In Texas the Mineral Lessee, Not the Surface Owner, Owns Produced Water

In Cactus Water v. COG Operating, the Supreme Court affirmed that mineral lessee COG, not water rights owner Cactus (who derived it rights from the surface owner), has the right to possession, custody, control, and...more

Ambiguity Frees Louisiana Royalty Owner From Post-Production Costs

In Franklin v. Regions Bank the Fifth Circuit concluded that a royalty clause in a mineral lease resulted in a gross proceeds royalty; the royalty owners did not bear their proportionate share of post-production costs. Read...more

How Did the 2025 Texas Legislature Address Energy?

Your Legislature has adjourned after enacting significant bills affecting the energy industry. To sum it up, the industry has friends in high places whenever the Lege is in session (Alternative energy was in jeopardy for a...more

Texas Operator Protected From Royalty Payment Error

The takeaway from DDR Weinert, Limited et al v. Ovintiv USA Inc. is that equitable recoupment rescued a royalty payor from its mistaken payment of royalties. But first, The events. The Richters were mineral lessors...more

Two Words = Six Million Dollars: SCOTX Reverses Trial Court That Added Words to a Gas Transportation Agreement

In American Midstream (Alabama Intrastate), LLC v. Rainbow Energy Marketing Corporation, the Texas Supreme Court held that the trial court improperly inserted the words “scheduled” and “physical” into a contract. By...more

Texas Supreme Court Decides Who Must Produce to Maintain an Oil and Gas Lease

In Cromwell v. Anadarko E & P Onshore LLC the Supreme Court of Texas did what it so often does: In order to provide “legal certainty and predictability”, the Court considered the plain language of a contract in order to...more

Operator Excused from Texas Relinquishment Act Claims

In Williams O & G Resources, LLC v. Diamondback Energy, Inc., a federal magistrate judge concluded that the Texas Relinquishment Act does not apply to public-school lands patented after 1931. The report and recommendation was...more

Texas Pore Space Ownership – Royalty Calculation

In Myers-Woodward, LLC v. Underground Services Markham, LLC et al, (discussed previously) the parties disagreed on how to calculate Myers’ royalty on salt produced by Underground....more

Who Owns the Subsurface Pore Space in Texas?

In a word, the surface estate owner. If that’s all the learning you are up for today, proceed directly to the musical interludes. If you want to know why the Supreme Court of Texas had to say this again, read on....more

Bad Guys in Energy Paid the Piper in 2024

As in every year, in 2024 the grinches of law enforcement brought financial and corporal misery to bad guys in energy. Here is a review of the crimes of only a few of the convicted, admitted and alleged bribsters, swindlers...more

Uri Force Majeure Cases Still Percolating

Thought you’d heard the last of force majuere cases arising from Winter Storm Uri? Think again. In Marathon Oil Company v. Koch Services LLC. the question was how to measure damages suffered by Koch for Marathon’s...more

Bankruptcy Court Blocks GLO’s State Lease Termination

In In re Pearl Resources LLC, a Houston bankruptcy court rejected the Texas General Land Office’s attempt to partially terminate state oil and gas leases in Pecos County, despite finding the operator had breached offset well...more

Geophysicist’s Claims Turn on Definitions

Sewak v. Sutherland Energy Co. Ltd. is of interest for how the court defined terms commonly used in consulting contracts in the oil and gas industry, and how difficult it is to foresee all contingencies when negotiating a...more

What’s the Difference Between a Mineral Reservation and an Exception?

The category is “terms that confuse us” for one hundred dollars. Without resorting to your favorite legal dictionary or lawyer, explain the difference between a reservation and an exception in a Texas warranty deed. Stumped?...more

Texas Court Shields Severed Mineral Interests from Tax Foreclosure Judgment

In Bush v. Yarborough Oil & Gas, LP a decades-old tax foreclosure judgment did not affect a previously severed mineral interest not owned by the delinquent taxpayer. The mineral owners were neither named nor served in the...more

Texas Court Extends Statutory Waste Provisions to Disposal Wells

We begin with a word from your sponsor. After enduring several generative AI tutorials, we urge you to keep on reading Energy and the Law. Why? Our blog is more accurate, at least a little “fun”, offers insightful musical...more

Marcel Exception to Louisiana Oilfield Anti-Indemnity Act Clarified

An understanding of Willis v. Barry Graham Oil Service LLC requires knowledge of two principles underlying the Louisiana Anti-Oilfield Indemnity Act: The LOAIA bars an oilfield agreement to the extent that the agreement...more

Texas Court Limits Tortious Interference Claims in Oil & Gas Assignment Dispute

The growling and barking presented by a claim for tortious interference is often far worse than the bite. Consider Segundo Navarro Drilling, Ltd. v. Chilton , which is a good example of that phenomenon in an oil and gas...more

How Does the Model Form JOA Address an Operator/Non-Operator Dispute?

Texas Crude v. Burlington Resources Oil and Gas considers the relationship between the operator and non-operators under Articles V and VI of the 1982 Model Form Joint Operating Agreement....more

Texas Supreme Court Allows Enforcement of a JOA Debt After Foreclosure

In Steelhead Midstream Partners, LLC v. CL III Funding Holding Company, LLC, the Texas Supreme Court authorized a pipeline owner’s breach-of-contract claim—alleging a co-owner used foreclosure to avoid cost-sharing...more

Scribner’s Error: A Cautionary Tale of Oil & Gas Fraud

DALF Energy, LLC v. GS Oilfield Services addresses a fiduciary’s deceptive actions in oil and gas transactions. The Fifth Circuit held: self-dealing may constitute a breach of fiduciary duty even when the principal is...more

Texas Mineral Buyer’s Due Diligence Falls Short

Patch LLC et al v. Indio Minerals LLC et al  was a dispute over title to a 1/8th NPRI in land in Midland County. Viola Ash, an Illinois resident, executed a warranty deed in 1932 for land in Midland County, reserving a 1/8...more

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