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When is a “Gross Proceeds” Royalty not Paid on Gross Proceeds?

Devon Energy Prod. Co., et al. v. Sheppard, et al is your kind of case if you are in search of: - A roadmap for slicing and dicing royalty calculations in myriad ways, - Pretty good summaries of the Supreme Court’s...more

“Construction” of a Well Pad Requires More than a Survey

In Evans Resources, L.P., et al. v. Diamondback E&P, LLC, two agreements left the terms “constructed” and “utilized” undefined. If the terms had been defined would the outcome have been different? Maybe. Should parties define...more

Limitations Bars an Heirship Proceeding

Estate of Trickett was a dispute over heirship of Claralyn Trickett, possibly the wife of Robert Bowerman (who must have forgotten to divorce his previous wife)....more

Terminological Inexactitude

When Winston Churchill used this phrase in 1906 in his speech to the House of Commons, he probably did not have in mind the construction of language contained in a deed. Nevertheless, terminological inexactitude in drafting a...more

Texas Supreme Court to Consider Continuous Development Clause

The Texas Supreme Court has agreed to hear oral arguments in a dispute over an “accumulation” provision in a continuous development clause of an oil and gas lease.  The case is Endeavor Energy Resources L.P. v. Energen...more

Offer to Acquire Leases Could Not be Conditioned on a JOA

From Great Western. Drilling, Ltd. v. Pathfinder Oil & Gas, Inc. we learn that if you want one agreement to be conditioned on execution of another one, you’d better say so … in writing … in the first one....more

“Provisional Authority” to Control Executive Rights Not Assignable

Geary v. Two Bow Ranch Limited Partnership* is an example of the havoc an unusual contract provision can create....more

Examining a Unit Operator’s Duties to an Unleased Mineral Owner

Samson Expl., LLC et al v. Moak considered the duties owed by a unit operator to an unleased mineral interest owner in tracts within the unit but on which no well is drilled or completed....more

Lessons from an Override Assignment

Contract construction cases are fact-specific, but one can take lessons of general application from all of them. Here are the takeaways from Jones Energy, Inc. v. Pima Oil & Gas, L.L.C....more

What Did the Mineral Deed Convey?

WTX Fund, LLC v. Brown, is Texas mineral deed construction case. In the same year that crazy thing happened at Coogan’s Bluff, the Roaches executed a Mineral Conveyance to the Holts. Let’s review the transaction and ask...more

Surrounding Circumstances Don’t Always Inform Deed Construction

Here we continue our discussion of the Texas Supreme Court’s opinion in Piranha Partners et al. v. Joe B. Neuhoff et al. determining that an assignment of an overriding royalty in minerals unambiguously conveyed the override...more

Texas Supreme Court Rejects “Rigid Rules” of Deed Construction

The question for the Texas Supreme Court in Piranha Partners et al. v. Joe B. Neuhoff et al. was whether an assignment of an overriding royalty in minerals conveyed the override only in production from the identified well...more

Coronavirus and the Energy Industry: Drilling into Force Majeure Clauses

Many oil and gas contracts – leases and JOAs for example – have force majeure clauses. The purpose is to allow contracting parties to suspend or terminate performance when certain circumstances arise that are beyond their...more

“No Obligation” Clause Dooms Oil and Gas Asset Bid

In Chalker Energy Partners III LLC v. LeNorman Operating LLC, the Texas Supreme Court reaffirmed its belief in the sanctity of the written contract and the freedom of parties to negotiate and agree to contracts as they...more

Texas Supreme Court Says Don’t Mess With a Written Contract

It is no surprise to Texas Supreme Court watchers that in Energy Transfer Partners et al v. Enterprise Products Partners LP et al. the court rejected claims that the parties had created a partnership by actions that varied...more

Keeping Score in Midstream Dedications in Bankruptcy: Midstreams 2, Producers 1

Ever since the Sabine Oil and Gas Corp. bankruptcy (the top of the first, If it were baseball), where a New York court construed Texas property law to hold that a gathering agreement was not a covenant running with the land,...more

Oil Field Services Gets Lump of Coal From Santa

Our sympathies go out to those in the oilfield services industry in Texas—it looks like you got a lump of coal. In Mesa Southern CWS Acquisition v. Deep Energy Exploration Partners the Houston Court of Appeals upended the...more

Mineral Royalties are Not “Personal Effects” in Texas

Confirming the obvious, in In re Etheridge a Texas court concluded that “personal effects,” in a last will and testament did not include mineral royalties. Let’s investigate how the case got this far....more

No Sovereign Immunity for the Texas Land Commissioner

Suing a state and its public officials is difficult because of the doctrine of sovereign immunity. There are exceptions. State of Texas v. Signal Drilling, et al. presents several of them....more

What is “Oil or Gas” as Used in a Pipeline Easement?

In Texan Land & Cattle II, Ltd. v. ExxonMobil Pipeline Company a Texas court of appeals ruled that “oil or gas” is not limited to “crude petroleum,” but includes refined petroleum products gasoline and diesel....more

Fake Mineral Leases Thwarted by the Texas Legislature

The 2019 Texas legislature enacted a new Property Code Section 5.152 to protect mineral and royalty owners from a certain species of fraudulent transactions perpetrated on trusting and/or naïve and/or out of state mineral...more

Louisiana Operator’s Bad Faith Does Not Preclude Recovery

Under Louisiana law, does the operator’s bad faith preclude recovery for the non-operator’s breach of a joint operating agreement if the operator caused the non-operator to breach the JOA but did not itself breach?...more

Midstream Dedications – Colorado Bankruptcy Court Levels the Playing Field

Until Monarch Midstream v. Badlands Energy, midstream companies facing rejection of their contracts in a producer’s bankruptcy were left with Abraham Lincoln’s least favorite negotiating option: If the both law and the facts...more

Spudding? Reworking? What are “Operations” Under an Oil and Gas Lease?

Quick answer: It depends on what the lease says.  Last week featured a tug-of-war between a producer and the community in which it operates; this week in HJSA No. 3 LP v. Sundown Energy LP  it’s the producer and the lessor....more

North Dakota: A Different Rule for Post-Production Costs In a State Lease.

What’s good for the goose is not always good for the gander, at least in some places. It appears that the North Dakota Supreme Court has adopted the minority “ Marketable Product Rule” in connection with a 1979 North Dakota...more

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