News & Analysis as of

Property Ownership Oil & Gas

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

Gray Reed

It’s Been Decided, In Texas the Mineral Lessee, Not the Surface Owner, Owns Produced Water

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In Cactus Water v. COG Operating, the Supreme Court affirmed that mineral lessee COG, not water rights owner Cactus (who derived it rights from the surface owner), has the right to possession, custody, control, and...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

Jackson Walker

Pore Some More: Current Legal Considerations of Pore Space Ownership in Texas

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Texas has been the leader in American energy independence for more than a century. Decades of industry innovation have provided Texas real property owners with new ways to extract value from minerals, water, and more...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

Bracewell LLP

Surface vs. Mineral Owners: Texas Supreme Court Settles Salt Cavern Ownership Dispute

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The Texas Supreme Court has settled the issue of who owns the voids, known as salt caverns, created in subsurface salt formations (whether naturally occurring or caused as a result of salt mining operations). In...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

Holland & Knight LLP

Texas Supreme Court: Subsurface Storage Rights Generally Belong to Surface, Not Mineral Owner

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The Supreme Court of Texas has provided helpful guidance as to ownership of subsurface storage rights and pore space. In the recent holding in Myers-Woodward, LLC v. Underground Services Markham, LLC, the court held that "the...more

Pillsbury - Gravel2Gavel Construction & Real...

From Shale to Salt: Texas Supreme Court Applies Uniform Rule for Ownership of Subsurface Caverns

In a closely watched opinion issued on May 16, 2025, the Texas Supreme Court in Myers-Woodward, LLC v. Undergrounds Services Markham, LLC, — S.W.3d —, No. 22-0878, 2025 WL 1415892 (Tex. May 16, 2025) resolved a long-uncertain...more

Gray Reed

Who Owns the Subsurface Pore Space in Texas?

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In a word, the surface estate owner. If that’s all the learning you are up for today, proceed directly to the musical interludes. If you want to know why the Supreme Court of Texas had to say this again, read on....more

McGinnis Lochridge

Who Owns the Empty Space? Texas Supreme Court Affirms Surface Ownership of Salt Caverns in Landmark Ruling

McGinnis Lochridge on

In Myers-Woodward, LLC v. Underground Services Markham, LLC, No. 22-0878, 2025 WL 4356581 (Tex. May 16, 2025), the Texas Supreme Court resolved two significant issues affecting mineral owners and surface owners: (1) who owns...more

Gray Reed

What’s the Difference Between a Mineral Reservation and an Exception?

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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

Gray Reed

Texas Supreme Court Will Review Produced Water Case

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Who owns produced water in Texas?  And what is produced water anyway – oil and gas waste and part of the mineral estate, or groundwater and part of the surface estate?  We may be closer to an answer to these questions now...more

Houston Harbaugh, P.C.

Pennsylvania Superior Court Reaffirms the Dunham Rule

Houston Harbaugh, P.C. on

Let’s assume you inherited a 150 acre farm in Lycoming County that has been owned by your family since 1909. In 2020, you are approached by ABC Drilling about a new oil and gas lease for the farm. You retain counsel and...more

Gray Reed

Texas Partition Suit Botched by Failure to Include an Owner

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When one tires of owning real estate with his co-owners, Texas law allows him the right to sue for partition of the property. In James et al v. Thornberry, 59.79 acres in Walker County, Texas, was owned by Ms. James and Mr....more

Oliva Gibbs

Bona Fide Victory: How a “Void” Deed Can Confer BFP Status in New Mexico

Oliva Gibbs on

In Koch v. David Fam. Oil & Gas Ints. P’Ship, the Court of Appeals of New Mexico held that the grantee in a deed of distribution executed by the foreign personal representative of an estate can be a bona fide purchaser in the...more

Houston Harbaugh, P.C.

The Neale Rule – Who Really Owns the Oil and Gas Under Railroads?

Houston Harbaugh, P.C. on

Since the early 1900’s, your family has owned a 105 acre farm in Greene County, Pennsylvania. In 2024, you and your siblings sign an oil and gas lease with XYZ Drilling Company. The language in the lease states that it...more

Gray Reed

Another Double-Fraction Texas Deed Case

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Davis v. COG Operating, LLC, in construing a Warranty Deed with a reservation of minerals, applied the estate-misconception doctrine and denied the presumed grant doctrine. At issue were three instruments...more

Gray Reed

Louisiana Federal Court Allows Injunctive Relief Under FERC Certificate of Public Convenience and Necessity

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Resistance was futile for defendants opposing a temporary injunction sought by a party armed with a FERC Certificate of Public Convenience and Necessity that includes condemnation rights under the Natural Gas Act....more

Gray Reed

Mother Hubbard Clause Saves a Property Deed

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Bell v. Midway Petroleum Grp., L.P., 9th Dist.] Mar. 18, 2021 was a trespass to try title action, suit to quiet title for possession of a land, and a counterclaim for title by adverse possession. ...more

Morgan Lewis - Power & Pipes

Supreme Court to Review Third Circuit’s ‘Disruptive’ NGA Decision on Pipeline’s Power to Acquire Right-of-Way over State Lands

The US Supreme Court granted certification on February 3 to review the US Court of Appeals for the Third Circuit’s decision in In re PennEast Pipeline Co. in order to resolve an important question: Does the Natural Gas Act...more

Gray Reed

Trespass Plaintiff: First, Prove Your Ownership

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Chauvin v. Shell Oil Company et al is the potful of legal unpleasantness that can be stirred up by landmen trying to buy easements, leases, and the like. A number of plaintiffs – descendants of grantors of two parcels of...more

Gray Reed

A Partition Deed Fails in Texas

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Cases like Hahn v. Gips et al are like eating your broccoli – not so tasty but lots of fiber. The “fiber” here is the effect of a partition deed in which not all the cotenants join....more

Gray Reed

Louisiana Partition Agreement: You Can’t Trade What You Don’t Own

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Square Mile Energy LLC v. Pommier considered this language in a Louisiana partition agreement: “N.B: Included in this transfer are any and all mineral rights, when available, to Roxanne and all surface rights.” Did this...more

Latham & Watkins LLP

Is Your ORRI What You Think It Is?

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Bankruptcy Court reinforces importance of parties’ intent in determining the nature of overriding royalty interests under state law. On April 2, 2015, the United States Bankruptcy Court for the District of Delaware...more

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