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Industry Custom Does Not Supersede Contract Language

In Barrow-Shaver Resources Company v. Carrizo Oil & Gas, Inc the Supreme Court of Texas has held again, here in a consent-to-assign dispute, that a contract means what the words say, even if in negotiations a landman said...more

Smart Pig Technology … and the Texas Merger Doctrine

Today is a two-fer. The questions: When does the “merger doctrine” not work in Texas, and how do courts treat technological developments created after a contract becomes effective?...more

Lessor, Should You Cash That Royalty Check?

Did the lessor’s deposit of royalty checks for production from a pooled unit that she contends was improper ratify the improper pooling? In Strickhausen v. Petrohawk et al, a jury will have to sort out the answer....more

The Difficulty of Enforcing an Unwritten Contract

Imagine how much better off you would be if the contract you want to enforce had been reduced to writing. See West v. Quintanilla for what happens when it wasn’t....more

Broad Settlement Discharges Mineral Liens

When you prepare, review and/or sign settlement agreements you sometimes pay less attention than you should to the details of those “standard” releases! Acme Energy Services, d/b/a Big Dog Drilling v. Staley et al. says,...more

Executive Right Holder Liable for Refusing to Lease

In resolving disputes among the mineral interest family, there is no bright-line rule delineating the duty of the executive right holder. In Texas Outfitters Limited v. Nicholson, the Texas Supreme Court explained why. The...more

What Does a Car Dealer Case Have to do With Oil and Gas?

In Mercedes-Benz USA, LLC, et al v. Carduco, Inc. dealership franchisee Carduco sued franchisor Mercedes Benz for fraudulent inducement and negligent misrepresentation. ...more

A Lesson in Property Stipulations

Marsha Ellison v. Three Rivers Acquisition, LLC, et al. reminds us what is required for an instrument to be a conveyance and what is required for a stipulation to be effective....more

Texas Court Addresses Bad Acts in a Lease Play

An opinion that observes “Obviously the jury was not overly enamored with Appellants.” is worth discussing. The decision is Stephens et al v. Three Finger Black Shale Partnership et al....more

Strip And Gore 2: The Sequel

We told you to “Beware of Strips and Gores” back in 2012 and today we bring you Green et al v. Chesapeake et al, the sequel. Unlike cinema’s greatest follow-ups, this entry feels more like an unneeded rehash of the original....more

Choice of Law Matters in an Oilfield Indemnity Suit

Did Texas law or New Mexico law apply to knock-for-knock indemnity provisions of a Master Work and Services Agreement? When a contract itself explicitly calls for Texas law, that is likely to be the outcome, as it was in...more

An Arbitration Ruling That’s About More Than Arbitration

In 2016 Ridge contacted the McDaniels (Double Eagle’s predecessors) with an offer to “lease” their mineral interests in Winkler County. The McDaniels informed Ridge about a producing lease from 2004, and were assured that it...more

Anti-Washout Clause Defeated by the Rule Against Perpetuities

Is an overriding royalty interest lasting beyond the term of a lease-now-in-effect impossible to create? You saw the recent Texas Supreme Court opinion invalidating an anti-washout clause in TRO-X v. Anadarko Petroleum Corp....more

Attempt to Prove a Texas Partnership Fails

Like breaking into CIA headquarters, sneaking into the Vatican, or hanging off the side of the Burj Khalifa, sometimes getting the deal done seems impossible. The key to any successful mission is planning for disastrous...more

Original Louisiana Lessee Can’t Escape Liability

Louisiana practitioners and their clients tend to know this particular point of Louisiana law, but it could surprise out-of-staters (known in their native habitat as “Texans”), so it’s worth a reminder...more

Texas Supreme Court Decides Another Fixed-or-Floating Royalty Case

Coke or Pepsi? Elvis or the Beatles? Left Twix or Right Twix? Fixed or floating royalty? Among the great debates of recent decades, few have proven quite as frustrating as the great “Fixed v. Floating” royalty debate in Texas...more

Redefining the Offset Well Clause, Part 2

As promised, here is a more in-depth analysis of the recent Supreme Court of Texas opinion in TRO-X LP v. Anadarko Petroleum Corp. ...more

Texas Supreme Court Affirms Washout of a Back–in Interest

We’re not saying you should do it, but there is a recipe for ridding oil and gas leases of pesky burdens: Enter into a new lease covering the same interest as the earlier lease and omit any reference to an intent that the...more

Texas Supreme Court Redefines an Offset Well Clause

In Murphy Exploration & Production Co. — USA v. Adams the Texas Supreme Court held that an offset well clause in an oil and gas lease did not require the lessee to drill wells calculated to protect against drainage. Four...more

Ask and You Shall (Not?) Receive: Retained Acreage Clauses and the Texas Supreme Court

Two Texas Supreme Court decisions published on the same day confirm that retained acreage clauses that vary in language from one instrument to another will likely vary in effect. Depending on the language, the lessee might...more

Foreclosure Included the Minerals Because the Documents Say So

In XTO Energy v. EOG Resources, a title dispute over the mineral estate in 1,653 acres in Atascosa and McMullen counties, Texas, the loser tried both, to no avail....more

NPRI Reservation Survives Rule Against Perpetuities

Recall the Battle of the Bastards: The heroic Lady Sansa and the duplicitous Lord Baelish gallop over the hill to save the foolish Jon Snow from the heinous Ramsey Bolton. In similar fashion, but without the malnourished...more

Mineral Title Examination – It’s Not Easy

Let’s get right to the takeaway: Despite the humble hourly rate operators are typically willing to fork over for title examination, the job isn’t easy and you’d better put your trust in a practitioner with expertise,...more

Can Emails Establish an Easement in Texas?

Email is the way we communicate these days. Whether emails create a contract is important if you’re thinking nothing short of a dead tree could ever bind anybody or, to the contrary, your goal is to establish an enforceable...more

Opinions to Expect From the Texas Supreme Court

The Texas Supreme Court recently heard oral argument in three intriguing oil and gas cases. Here’s what you need to know about two of them (We’ll address the third case soon)....more

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