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Texas Court Splits Family Timber Land Over Heir’s Objections

“He who comes for the inheritance is often made to pay for the funeral”.* When heirs inherit property together and can’t agree on its use, Texas courts strongly prefer dividing the land physically rather than forcing a sale,...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

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 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

Ratifications, Stipulations, and Fixed vs. Floating Royalty Interests

After four stops at the lower courts, Kenneth Hahn v. ConocoPhillips has been resolved by the Supreme Court of Texas. The Court opined on the effect of two instruments often used to clarify land titles in Texas: ...more

Wind Farms: NIMBY Unless You Ask Permission

For the Osage Indian Tribe, it’s more like “IMBY if you pay me”.  In the latest interation of United States and Osage Minerals Council v. Osage Wind LLC et al the US District Court for the Eastern District of Oklahoma awarded...more

Misspelled Name Leads to Land Title Chaos

Carson et al v. Winter Gordon, Junior is a reason you should not name your son after yourself. But if you insist, at least spell his name correctly. ...more

An Oil and Gas Receivership Ain’t Over ‘Til It’s Over

Remnant LLC v. Permico Royalties LLC, et al determined that a 90-year-old claim to ownership of a forfeited corporation was not valid. The players - Hoffman: By most accounts a scoundrel and con man who plied his...more

How Courts Look at Fixed or Floating Royalty Disputes

Montgomery Trustee v. ES3 Minerals and Echo Minerals is another Texas fixed or floating royalty case. Before diving into the details, perhaps it’s best to describe the pattern the courts seem to fall into to resolve these...more

Agreed Judgment and Division Order Don’t Avoid Double Royalty Payment

So, you found all the heirs and you have an agreed judgment stipulating title. Time to pay royslties? Maybe. And you have signed division orders. Surely, you can pay now? Maybe. These were the questions facing the parties in...more

What Makes a Reservation a Mineral Interest and not a Royalty?

We begin with a document-drafting tip: When reserving an interest in minerals, before cutting and pasting from your old document that would be yellowed and dusty if it remained in its original papyrus format, lawyers and...more

9/15/2023  /  Land Titles , Minerals

Texas Correction Deed Statute Revisited … Again

You might recall this post on Broadway National Bank, Trustee v. Yates Energy Corporation. We now have Yates Energy Corporation et al v. Broadway National Bank, Trustee, the court of appeals’ ruling after remand. Recall the...more

Busted Land Transaction Violated the Statute of Frauds

In the Estate of Terry Banta presents yet another purported Texas land transaction doomed because of disregard for the Statute of Frauds. Terry Banta and the Herriotts entered into an oral agreement for the Herriotts to...more

Price is Paid for Failure to Timely Probate a Texas Will

 In re: Estate of Robert Scott Masters, Deceased reveals the price to be paid for failing to timely admit a will to probate or as a muniment of title. Know this about Texas probate law - The Estates Code requires...more

Texas Supreme Court Rules on Correction Deeds in a Case of First Impression

What if you pay good money for a mineral interest and record the deed in the official public records, thereby securing your title? What if your predecessors-in-title decide among themselves they made a material mistake in a...more

A Different Lesson in Property Stipulations

The Texas Supreme Court in Concho Resources, Inc. v. Ellison enforced a boundary stipulation involving an unambiguous deed about which there had been no dispute. You can refer to our earlier post to understand the facts, the...more

Texas Court Parses Three Retained-Acreage Clauses – Part 2

Yesterday we discussed aspects of PPC Acquisition Co., LLC, et al. v. Delaware Basin Res., LLC, et al. Today we consider whether the retained-acreage clauses created a special limitation or a covenant and the relationship...more

Fixed-or-Floating NPRI Principles Applied to Texas Mineral Reservation

In Susan Davis Van Dyke et al. v. The Navigator Group. et al., the Eastland court of appeals applied recent fixed-versus-floating NPRI principles to a double-fraction mineral interest reservation....more

A Unique Discovery Request in a Texas Water Rights Fight

In re Plains Pipeline, L.P., is a suit to adjudicate title to groundwater. Did the trial court err in allowing a party to drill seven test holes on a tank farm? (Spoiler alert: It didn’t.) This decision evaluates an order in...more

Partition Agreement Outweighs Coal Surface Destruction Test

In Wheeler et al v. San Miguel  Electric Cooperative, we learn – again – the difficulty in asserting a position in litigation that is contrary to the actual words in the agreement you are fighting over....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

Family History Guides Interpretation of a Texas Will

Generally, if your will leaves your beloved “all … right, title and interest in and to”, said beloved would receive the entirety of your interest, whether a surface estate, mineral estate, or both. But in ConocoPhillips, et...more

Strip and Gore Doctrine: Infinity War

Yet another entry in the Strip and Gore universe (2012’s “Beware of Strips and Gores”, and 2019’s “Strip and Gore 2: The Sequel”) comes to us from Fort Worth Court of Appeals: Richard D. Crawford v. XTO Energy, Inc....more

Limitations Title Not Precluded by Late Acknowledgment

Scribner v. Wineinger, et al. affirms that acquisition of a Texas oil and gas leasehold by limitations is not defeated if the adverse possessor’s acknowledgement of a claimant’s title comes too late....more

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