News & Analysis as of

Appeals Texas Oil & Gas

Mitchell, Williams, Selig, Gates & Woodyard,...

Liquid Natural Gas Plant/Clean Air Act: Fifth Circuit Court of Appeals Addresses Challenge to Texas Commission on Environmental...

The United States Court of Appeals for the Fifth Circuit (“Fifth Circuit”) addressed in an August 12th Decision a challenge to a Clean Air Act Prevention of Significant Deterioration (“PSD”) Permit issued by the Texas...more

Gray Reed

A Lesson on How Not to Recover an NPRI in Texas

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It seems to be fairly well settled that you can’t use trespass-to-try-title to recover a nonpossessory royalty interest in Texas. What if you call the interest a “mineral interest stripped of every attribute except the right...more

McGinnis Lochridge

When "Imprudent" Becomes Irrelevant: How Express JOA Language Overrides Operator Discretion

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In this case, Texas Crude Energy, LLC (Texas Crude) and Warwick-Athena, LLC (Warwick) (collectively, the non-operators) sued Burlington Resources Oil & Gas Co., LP (Burlington or the operator) after Burlington refused to...more

Bracewell LLP

Texas Supreme Court Affirms Mineral Estate Ownership of Produced Water in Landmark Ruling

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In a significant decision for Texas property and energy law, the Texas Supreme Court has affirmed the Eighth Court of Appeals’ ruling in Cactus Water Services, LLC v. COG Operating, LLC, holding that produced water — a...more

McGinnis Lochridge

Are Statute of Limitations Battles Becoming the New Frontline in Water Injection Cases?

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When your neighbor's wastewater tanks your oil wells, when exactly can you sue? A Texas court wrestles with a timing question reshaping industry battles....more

Vinson & Elkins LLP

Texas Supreme Court Clarifies Ownership of Salt Caverns

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On May 16, 2025, the Texas Supreme Court issued a decision ruling that, absent specific contractual language, surface owners retain ownership of the caverns created by salt mining operations. The issue of ownership of salt...more

Troutman Pepper Locke

Fifth Circuit Finds ANR Pipeline’s Tariff Does Not Require Simultaneous Delivery for Short-Notice Shipments

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On May 22, 2025, the U.S. Court of Appeals for the Fifth Circuit (“Fifth Circuit”) addressed a dispute between ANR Pipeline Company (“ANR”) and FERC. The case centered on the interpretation of ANR’s tariff and whether it...more

Gray Reed

Texas Supreme Court Decides Who Must Produce to Maintain an Oil and Gas Lease

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In Cromwell v. Anadarko E & P Onshore LLC the Supreme Court of Texas did what it so often does: In order to provide “legal certainty and predictability”, the Court considered the plain language of a contract in order to...more

McGinnis Lochridge

Supreme Court of Texas Washes Out the “Anadarko Washout”

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The so called “Anadarko Washout” involves a washout of oil and gas leases on undivided working interests owned by non-operating mineral cotenants. This particular species of lease washouts is based on two recent cases from...more

McGinnis Lochridge

Texas Supreme Court Clarifies Limits of Shut-In Payment Notations in Lease Disputes

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In this case (Scout Energy Mgmt., LLC v. Taylor Properties, No. 23-1014, 2024 WL 5249490 [Tex. Dec. 31, 2024]), the Texas Supreme Court held that vague notations on shut-in royalty check receipts cannot modify an unambiguous...more

McGinnis Lochridge

Production Disputes and Estoppel Claims Cloud Lease Termination in Milam County

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In this lease termination case (Pruett v. River Land Holdings, LLC, No. 03-22-00478-CV, 2024 WL 1745652, at *1 [Tex. App.—Austin Apr. 24, 2024, no pet.]), the Austin Court of Appeals was tasked with examining a cessation of...more

McGinnis Lochridge

All Depths or Just One Formation? Court Clarifies Royalty Conveyance in Rock River v. Pioneer

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This recent case (Rock River Minerals, LP v. Pioneer Nat. Res. USA Inc., No. 08-23-00216-CV, 2024 WL 4528917 [Tex. App.—El Paso Oct. 18, 2024, no pet. h.]) explored whether an assignment of an overriding royalty interest,...more

McGinnis Lochridge

Affirmative Defenses Are Insufficient to Rebut the Van Dyke Presumption

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Under Van Dyke, deeds with double-fraction royalty reservations referencing “1/8” are presumed to reserve a floating royalty interest unless clearly contradicted. Defenses like waiver, ratification, and limitations cannot...more

McGinnis Lochridge

Can "Free of Cost" Term Achieve Point-of-Sale Royalty Base?

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A lessee who halts production for less than 40 days and resumes without drilling or reworking does not terminate the lease. The continuous development clause keeps the lease active, and the cessation clause allows resumed...more

McGinnis Lochridge

Drowning in Liability: Court Extends "Waste" Rule to SWD Operator; but preserves RPO defense

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In a watershed ruling, the El Paso Court of Appeals extends "waste" liability under the Nat. Res. Code to commercial disposal well operator—potentially increasing exposure for this critical wastewater industry—while...more

Oliva Gibbs

Reservation or Limitation on Warranty? Navigating the Fine Line — Lessons from Valence Operating Co. v. Davidson

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In Valence Operating Co. v. Davidson1, the Court of Appeals for the Sixth Appellate District of Texas at Texarkana addressed whether the provision, “all Oil, Gas and other Minerals have been excepted and reserved by former...more

McGinnis Lochridge

Tackling Free-Use and At-The-Well Royalties

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This lease royalty case involved a dispute over whether the lessee was permitted to deduct volumes of gas used off the premises to power post-production activities on other gas produced from the same well. Carl v. Hilcorp...more

Carlton Fields

Texas Appeals Court Finds Project Owner Excluded From Coverage as Claimants’ Statutory Employer

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On April 3, 2025, a Texas state appeals court reversed a trial court order awarding Exxon Mobil $25 million under an umbrella insurance policy issued by Lexington Insurance Co. to Brock Services Ltd. The appeals court found...more

Gray Reed

Texas Court Extends Statutory Waste Provisions to Disposal Wells

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We begin with a word from your sponsor. After enduring several generative AI tutorials, we urge you to keep on reading Energy and the Law. Why? Our blog is more accurate, at least a little “fun”, offers insightful musical...more

Vinson & Elkins LLP

Brine Time: Texas’ Latest in Lithium Law

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Lithium continues to be a rising star of the natural resources world, and Texas is working to stay on top of the legal issues related to the extraction of lithium from produced water and brine. In this update, we discuss...more

Gray Reed

Texas Court Limits Tortious Interference Claims in Oil & Gas Assignment Dispute

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The growling and barking presented by a claim for tortious interference is often far worse than the bite. Consider Segundo Navarro Drilling, Ltd. v. Chilton , which is a good example of that phenomenon in an oil and gas...more

McGinnis Lochridge

Who Can Enforce Surface Provisions in an OGL?

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Unitex WI, LLC v. CT Land & Cattle Co., LLC, No. 07-23-00390-CV, 2024 WL 3249338 (Tex. App.—Amarillo June 28, 2024, pet. filed)...more

McGinnis Lochridge

Winter Storm Uri and Force Majeure: The Legal Battles Continue

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Winter Storm Uri sent shockwaves through Texas, freezing gas supplies at a time of critical need and plunging the state into widespread power outages. In the aftermath, the courts have been flooded with force majeure claims,...more

Gray Reed

What Will the Texas Supreme Court Say About Allocation and PSA Wells?

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Alas, we might never know. Opiela v. Railroad Commission of Texas and Magnolia Oil & Gas Operating, was a challenge to the Commission’s authority to issue permits for allocation wells and wells drilled under Production...more

Oliva Gibbs

Coverting a “Fixed” to a “Floating” NPRI: What (If Anything) Does ConocoPhillips v. Hahn Add to the Conversation?

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In ConocoPhillips Co. v. Hahn, the Supreme Court of Texas addressed whether a “fixed” nonparticipating royalty interest (“NPRI”) was later converted to a “floating” NPRI. The court weighed two possible means of this...more

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