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“Floating” Beats “Fixed ” in Texas Royalty Reservation

If you are scoring at home, count Permico Royalties LLC v. Barron Properties, Ltd., as a win for “floating” in the fixed-or-floating royalty battles. Permico, successor to grantors in a 1937 Deed for a tract in Ward County,...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

Winter Storm Uri – No Summary Judgment This Time

Unit Petroleum Company v. Koch Energy Services, LLC is another force majeure case arising out of winter storm Uri. Unlike a similar case, summary judgment was denied because, said the United States District Court, The word...more

Texas Landowner Enjoined from Interfering with Lessee’s Operations

Davenport v. EOG Resources, Inc. is an appeal of a temporary injunction. The title tells you the result. Davenport owned four tracts comprising 5,000 acres in Webb County that were originally part of a larger tract...more

Who Owns Produced Water in Texas?

In Cactus Water Services LLC v. COG Operating, LLC., a divided Texas court of appeals answered the question this way: The oil and gas producer prevails over the purchaser of the surface owner’s right to own and sell produced...more

Will the Fixed or Floating Suits Ever End?

Rhetorical Question: When will Texas be done with fixed/floating royalty cases such as Johnson et al v. Clifton et al? Rhetorical Answer: When scriveners of deeds that are open to eight conceivably plausible meanings...more

Federal Court Distinguishes Devon v. Sheppard

Producers disappointed by the Supreme Court’s holding in Devon Energy Production v. Sheppard might have reason to feel vindicated. The question in HL Hawkins Jr., Inc. v. Capitan Energy Inc. et al. was whether producer...more

“Harmony” in a Texas Mineral Reservation

In Smart v. 3039 RNC Holdings LLC, the court reminds us that it will harmonize all parts of a contract, even one that “is not a model of clarity”, to reach the correct result. ...more

Supreme Court of Texas Tackles the Meaning of “Predecessors”

The plain, ordinary, and generally accepted meaning of a word doesn’t mean “anything goes”. It depends on context, says the Supreme Court of Texas in Finley Resources Inc. v.  Headington Royalty Inc., a dispute over the...more

California Brings Legislative Muscle To Its Attack on Oil Drilling

California has passed Senate Bill 1137, which will prohibit drilling of new oil and gas wells and reworking of existing wells in certain areas. Here is SB 1137 in legislativese (analysis comes first, then the text)...more

Will the New Texas Business Court Impact Oil and Gas Cases?

The Texas Legislature has created a new Texas Business Court (the TBC) with jurisdiction over cases involving certain qualified (as in “big-dollar”) business transactions. HB 19 could affect large oil and gas cases; how and...more

Court of Appeals Rules on Texas PSA Well Permit

The Austin Court of Appeals has ruled in Texas Railroad Commission et al v. Opiela, the dispute over a permit for a horizontal well under a Production Sharing Agreement.  We reported on the result in the trial court. Here are...more

How to Lose Your Working Interest in 26 Annual Steps

Can a non-operating working interest in a Texas oil and gas lease be adversely possessed? The Amarillo Court of Appeals said yes in PBEX II, LLC v. Dorchester Minerals, L.P....more

Texas Tax Man Catches up with Leasehold Seller

Texas, famously, does not tax individuals’ income, but it does impose franchise taxes on “taxable entities”, such as limited liability companies. Federal tax law treats them as partnerships unless they elect to be treated...more

JOA Cross-Netting Question Almost Answered

One of the questions raised in 1776 Energy Partners, LLC v. Marathon Oil EF, LLC was whether Marathon as operator could apply revenues owed to non-operator 1776 under one joint operating agreement to satisfy unpaid debts owed...more

Appeals Court Revives Lessor’s Fraud Claims

Tips on litigation avoidance: Not making promises you don’t intend to keep is easy enough. Stating a fact or making a promise and things change, you could be a fraudster if you don’t come clean before closing....more

Texas Supreme Court Rules on Suspension of Proceeds of Oil and Gas Production

Freeeport-McMoRan Oil and Gas, LLC and Ovintiv USA Inc. v. 1776 Energy Partners LLC  presented a recurring question faced by Texas oil and gas producers:  When can proceeds of production be withheld by the operator without...more

A Day Made a Difference in This Purchase and Sale Agreement

And what a difference it was! In Apache Corp. v. Apollo Expl. LLC et al, Apache and others acquired an oil and gas lease on 100,000+ acres in the Texas Panhandle. The primary term was three years. The effective date was...more

Climate Litigation Update

You might recall our posts on litigation by states, counties, and cities blaming a host of calamities, real and imagined, past and future, on Big Oil. The producers tried their best to remove the cases to federal court. In a...more

Lessee Can’t Satisfy Texas Supreme Court’s Force Majeure Requirements

Imagine these facts in a force majeure dispute (as presented in Point Energy Partners Permian LLC et al. v. MRC Permian Company). Lessee (MRC) invokes the force majeure provision of an oil and gas lease, asserting that...more

Texas Supreme Court Decides Arbitrability of Offshore Agreements

In TotalEnergies E&P USA, Inc. v. MP Gulf of Mexico LLC. the Supreme Court of Texas resolved the chaos created by conflicting dispute resolution regimes in three contracts for ownership and operation of an offshore unit and...more

Ohio Federal Court Considers Subsurface Trespass

Golden Eagle Resources II LLC v. Rice Drilling D LLC. presents a small step in the development of subsurface trespass law in Ohio. The federal court considered a motion to dismiss, in which it evaluated the sufficiency of the...more

Insurance Coverage Not Limited by a Texas Service Agreement

As you negotiate your master service agreements are you confident that you know how insurance choices might affect indemnity obligations? Me neither. That’s why I turn to my Gray Reed partner Darin Brooks and his insurance...more

More Force Majeure Fallout From Uri

MIECO, LLC v. Pioneer Natural Resources presented a challenge to a force majeure defense in a dispute arising from Winter Storm Uri. The defense carried the day....more

“All Means All” in Construing an Assignment of Leases

In a recurring theme, harmony and the four-corners rule were front and center in Citation 2002 Inv. LLC et al v. Occidental Permian, Ltd. et al, a case of competing claims over the granting language in an assignment of oil...more

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