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Waiting Too Long to Sue For a Working Interest is a Loser

Delay in filing suit too often spells doom for the plaintiff, as we learn in Zadeck Succession et al v. Treme et al. Treme (as in the family collectively) claimed their father, Vandiver, was conveyed a 5% working...more

Who Bears the Burden of a Newly Discovered Non-Participating Royalty Interest?

The question in Brooke-Willbanks v. Flatland Mineral Fund LP, et al was which party to a Texas mineral deed would bear the burden of two previously reserved nonparticipating royalty interests....more

Texas NPRI Not Diminished by Pooling Ratification

The takeaway from Hahn v. ConocoPhillips Company is that in Texas a NPRI holder may not diminish his rights by ratifying pooling of an oil and gas lease unless there are provisions explicitly purporting to do so....more

Louisiana Royalty Owner Survives Challenge to Demand For Payment

The question in Kim R. Smith Logging Inc. v. Indigo Minerals LLC  was whether a disgruntled Louisiana royalty owner sent its demand for unpaid royalties to the right party.  It turns out that it did....more

Oops! Sellers Didn’t Read The Mineral Deed Before Signing

Precious little legal analysis is required to grasp the lesson from Springbok Royalty Partners v. Cook.  No mode or manner of legal gymnastics is likely to save parties from the legal effect of a contract they didn’t bother...more

The “Greatest Estate” Doctrine Impacts a Lease Assignment

Let’s begin with some Texas law on what a seller sells when he executes a deed: Generally, a Texas real property deed will confer upon the grantee the greatest estate as the terms of the instrument will permit. This...more

A Texas Fight Over Competing Leases

Let’s proceed directly to the takeaways from Fort Apache Energy, Inc. v. Short OG III, Ltd., et al, a Southern District of Texas bankruptcy court opinion. (Gray Reed partners Jim Ormiston and David Leonard represented Short...more

Exxon’s Attempt to Create New Sale/Lease Tax Law Fails

The principal contention in the tax refund case of Exxon v. United States was whether certain mineral related transactions between Exxon and the countries of Qatar and Malaysia were sales or leases.  Originally Exxon treated...more

Market Value at the Well Trumps Free-Use Clause

The common thread throughout the myriad oil and gas royalty cases decided recently by Texas courts could be “harmony”, the reading of different, seemingly conflicting, contract provisions so as to give meaning to all....more

Beware Assignor: Own the Leases Before You Reserve the Override

Let’s begin with a quiz. Armour purchases non-recourse mortgage notes, becoming a lienholder in 99 oil and gas leases and 13 wells; fails to record the transfer documents in the real property records; assigns the leases to...more

City of Dallas Owes $33+ Million for Drilling Permit Denials

If you have ever wondered how many ways a cocktail of stupidity*, treachery and feckless government can inflict financial harm on the undeserving, including the citizens the feckless government leaders are supposed to serve,...more

Arbitration Over Offshore Leases Does Not Warrant Lawsuit Dismissal

Just because parties agree that disputes over a contract will be subject to binding arbitration doesn’t mean there won’t be wrestling at the courthouse beforehand. In LLOG Exploration Offshore, LLC v. Samson Contour Energy...more

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

Texas Correction Deed Statute Revisited

Those who continue to be horrified by Broadway National Bank, Trustee v. Yates Energy Corp. should be relieved that the result in Endeavor Energy Resources, LP v. Anderson was more equitable. In Yates, the Texas Supreme Court...more

Court Finds Declaratory Judgment Action, Not Trespass to Try Title

SM Energy Co. v. Union Pac. R.R. Co. considers a question frequently asked in Texas suits affecting title: When is a suit a trespass to try title action and not a declaratory judgment action?...more

Were the Mineral Deeds a Gift or a Sale? It Made a Difference.

The question presented in Aaron v. Fisher et al: Did mineral deeds bestow separate property upon the grantees by gift, or did they convey a community property interest to the grantees and their spouses by sale for...more

Royalty Obligations on Free-Use Gas Redux

Recall our recent post on Carl v. Hilcorp Energy Company from the U.S. District Court for the Southern District of Texas discussing the lessee’s royalty obligations on gas used off the premises in a market-value lease. See...more

No Off-Lease Gas Use Recovery For Royalty Owners

The question is presented again but in a different format: In Texas is a lessee allowed to deduct post-production costs (PPC’s) from the lessor’s gas royalty? In Carl v. Hilcorp, the answer was “yes” based on the language in...more

Clause to Protect Against Drainage in a Mineral Lease Deemed Ambiguous

Today we will skip our usual routine of explaining how court rulings on the question of the day might affect your interests. Instead we will discuss the fallout from abysmal document drafting. In Rosetta Resources Operating...more

Lease Perpetuated Beyond Primary Term Without Production in Paying Quantities

If perpetuation of a mineral lease beyond the primary term is contingent upon continuous operations, do traditional notions of “production in paying quantities” always matter? Spoiler: No....more

Most-Favored-Nations Clause Costs Lessee

This “most-favored-nations” clause in three oil and gas leases on land in LaSalle County, Texas, was at issue in EP Energy E&P Co., L.P. v. Storey Minerals, Ltd. ...more

The Meaning of “Subject To” in a Deed

Commonwealth of Pennsylvania v. International Development Corporation resolved the question, In a 100 year old Pennsylvania deed is a “subject to” provision an exception to a grant or a warranty disclaimer?...more

Ohio Landowners Burdened with Post-Production Costs

Zehentbauer Family Land, LP v. TotalEnergies E&P USA, Inc. is a story we’ve heard before: Royalty owners contend they are not getting a big enough slice of the hydrocarbon pie, which presents a question courts must answer:...more

Louisiana Unit Operators May Deduct Post-Production Costs from Unleased Mineral Owners

The question with wide-ranging implications for Louisiana operators and mineral owners in Johnson et al. v. Chesapeake Louisiana LP et al is whether unleased mineral owners in a drilling unit established by the Commissioner...more

Stray Cows and Oilfield Operations Do Not Play Well Together

Foote and Cypert v. Texcel Exploration and Decker determined that cattle loitering uninvited around a well and tank battery are trespassers, not licensees. How it happened - Foote arranged with Yates to graze 650 head...more

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