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Oil & Gas Deeds

Oliva Gibbs LLP

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

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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

Houston Harbaugh, P.C.

The Centerline Presumption – Who Really Owns the Oil and Gas Under Roads and Highways? (Part II)

A troubling and confusing issue here in Pennsylvania concerns the ownership of oil and gas rights under roads and highways. For example, let’s assume Farmer Joe owned 115 acres in Greene County. In 1981, Farmer Joe sells...more

Houston Harbaugh, P.C.

West Virginia Appellate Court Rules That Estate Misconception Theory Did Not Apply To 1902 Deed

The calculation of production royalties and the deduction of post-production costs remains a troubling issue for Pennsylvania landowners. But there is another frustrating and often confusing royalty-related issue which can,...more

Oliva Gibbs LLP

Double Reservations and Double Fractions: Ohio Appellate Court Addresses Complex Fixed vs. Floating Royalty Interest Debate

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The Ohio Seventh District Court of Appeals recently came down on (yet another) dispute between fixed fractional and floating royalty reservations. The case of Min. Dev. Inc. v. SWN Prod. (OHIO), LLC, et al., overturned a...more

Gray Reed

Court Addresses Questions in Trespass to Try Title/Adverse Possession Suit

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Fletcher v. Merritt resulted in several rulings on the proof required to prevail in a property dispute. Merritt filed a trespass to try title suit (actually a quiet title, which the court construed as TTT) against Fletcher...more

Gray Reed

Defense of a Deed Signed by a 12-Year-Old Fails

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Foreshadowing a grim future for family weddings and funerals, Bell and Petsch v. Petch is a property dispute over five tracts of land in Gillespie County, Texas, in which siblings are the combatants. The events are less...more

Gray Reed

“Floating” Beats “Fixed ” in Texas Royalty Reservation

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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

Houston Harbaugh, P.C.

Pennsylvania Superior Court Clarifies Nature of Oil and Gas Lease Under Pennsylvania Law

Let’s assume you own a 160-acre farm in Washington County. Your father purchased the farm in 1992 from a local farmer named Jones. (the “1992 Deed”). At the time your father purchased the farm, there was an oil and gas lease...more

Gray Reed

Will the Fixed or Floating Suits Ever End?

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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

Houston Harbaugh, P.C.

The Strip and Gore Doctrine - Who Really Owns The Oil and Gas Under Roads and Highways?

Houston Harbaugh, P.C. on

Let’s assume your grandfather owned 99 acres in Washington County. In 1955, he sells a small portion of the farm to the Commonwealth of Pennsylvania in order to facilitate the construction of new State Route 39. This acreage...more

Houston Harbaugh, P.C.

Texas Supreme Court Rules That 1924 Deed Conveyed One Half Of The Oil and Gas Estate

Houston Harbaugh, P.C. on

The calculation of production royalties and the deduction of post-production costs remains a controversial topic here in Pennsylvania. As we have written before, there is another frustrating and often confusing...more

Gray Reed

The “Greatest Estate” Doctrine Impacts a Lease Assignment

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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

Gray Reed

Texas Correction Deed Statute Revisited … Again

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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

Gray Reed

Texas Correction Deed Statute Revisited

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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

Gray Reed

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

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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

Gray Reed

Texas Mineral Deed Signed Away Right to Sue

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The question in litigation is usually “WHAT”: what happened, what contract was breached, what did someone do or fail to do, and so on. In Hughes v. CJM Resources, LP, the question was, “WHO” had the right to file the suit in...more

Gray Reed

The Meaning of “Subject To” in a Deed

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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

McGlinchey Stafford

Does CAFA permit appellate review of sua sponte remand orders? - Commercial Law Bulletin, April 5 2022

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Ohio- Substantially compliant acknowledgment clause WWSD, LLC v. Woods, 10th Dist. Franklin No. 20AP-403, 2022-Ohio-952- In this appeal, the Tenth Appellate District affirmed the trial court’s decision, agreeing that...more

Steptoe & Johnson PLLC

Ohio Supreme Court Decision Provides Further Clarity on the Common Law Distinction Between a Reservation and an Exception

On February 15, 2022, the Supreme Court of Ohio issued its decision in Peppertree Farms, L.L.C., et al. v. Thonen, et al., providing further clarity on the common law distinction between a “reservation” of a property interest...more

Gray Reed

Texas Supreme Court Clarifies Postproduction Cost Decision

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It was jurisprudential Groundhog Day as the Supreme Court of Texas handed down Nettye Engler Energy v. Bluestone Natural Resources, another in a series of postproduction cost disputes, only two days after Puxsutawney Phil...more

Gray Reed

Try Title vs. Quieting Title: What’s the difference?

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If you aren’t quite sure about the difference between trespass to try title and suit to quiet title, Lockhart as Tr. of Lockhart Fam. Bypass Tr. v. Chisos Mins., LLC  explains. ...more

Gray Reed

Texas Supreme Court Rules on Correction Deeds in a Case of First Impression

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What if you pay good money for a mineral interest and record the deed in the official public records, thereby securing your title? What if your predecessors-in-title decide among themselves they made a material mistake in a...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

Gray Reed

Texas NPRI Burdened with Post-Production Costs

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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

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