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ExxonMobil Discovers That Amended Tax Returns Are Dangerous

In Exxon Mobil Corp. v. United States of America, from the United States District Court for the Northern District of Texas, ExxonMobil learned the hard way that filing amended tax returns can be very costly....more

Texas Supreme Court Deems Continuous Development Clause Ambiguous

In Endeavor Energy Resources, L.P. v. Energen Resources Corp. et al. the Supreme Court of Texas construed a continuous development clause in an oil and gas lease covering 11,300 acres in Howard County. After the primary term,...more

Contaminated Butane and Propane Creates Fight Over General Terms and Conditions

Enterprise Products Operating v. Trafigura, A G. asks, Who should pay when a “black blob” that had “the stench of a skunk” was left behind after $27 million worth of an odorless product is delivered from a ship?...more

Texas NPRI Burdened with Post-Production Costs

BlueStone Nat. Res. II, LLC v. Nettye Engler Energy, LP is another Texas case deciding whether language creating a nonparticipating royalty interest prohibited deduction of post-production costs. (Spoiler alert: it didn’t....more

Texas Court Evaluates Consent to Assign an Oil and Gas Lease

In Mayo Found. For Med. Educ. & Research v. BP Am. Prod. Co. a United States District Court considered the circumstances under which a lessor can withhold its consent to assign an oil and gas lease....more

My Operator is Making Money … Part 2, The Operator’s Response

The threat: You, the operator, are operating unprofitable wells where monthly costs exceed or barely equal revenues, making money on the fixed COPAS overhead charges. Your non-operators are going into the economic hole and...more

My Operator is Making Money on the Well and I’m Not. What Can I Do? Part 1.

With the plunge in commodity prices many formerly profitable wells are now in the red, and we don’t know for how long. This is causing non-operators to question the bona fides of the operations … and of the operator, and to...more

Lignite Lease Prevails Over Pipeline Easement

San Miguel Electric Coop is a Texas nonprofit electric cooperative that owns and operates a power plant that supplies electricity to 38 Texas counties. After a four-week absence, they return to these pages, this time in DCP...more

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

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

“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

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

Louisiana Servitude Extended by Good Faith Drilling

The question in Cannisnia Plantation, LLC v. Cecil Blount Farms, LLC was whether a well was drilled in good faith in order to interrupt the running of prescription on a Louisiana mineral servitude....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

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

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

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

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