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NPRI Plaintiff Survives Affirmative Defenses

Boren Descendants et al v. Fasken Oil and Ranch, LTD, offers something to talk about beyond interpretation of the fixed-or-floating NPRI question.  At issue was this reservation, expressed as a double fraction, in a 1933...more

Ratifications, Stipulations, and Fixed vs. Floating Royalty Interests

After four stops at the lower courts, Kenneth Hahn v. ConocoPhillips has been resolved by the Supreme Court of Texas. The Court opined on the effect of two instruments often used to clarify land titles in Texas: ...more

Texas Supreme Court Will Review Produced Water Case

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

Wind Farms: NIMBY Unless You Ask Permission

For the Osage Indian Tribe, it’s more like “IMBY if you pay me”.  In the latest interation of United States and Osage Minerals Council v. Osage Wind LLC et al the US District Court for the Eastern District of Oklahoma awarded...more

Louisiana Operator Survives Forfeiture of Right to Recover Drilling Costs

In Mistretta v. Hilcorp Energy Company, unleased mineral owner Mistretta sued Hilcorp alleging failure to provide requested production and well cost information pertaining to an oil well operated by Hilcorp. The well was in a...more

Choice of Words Matters in an Override Assignment

The question in Rock River Minerals, LP and Carr v. v. Pioneer Natural Resources, et al.: Did an assignment of overriding royalty interests in Texas oil and gas leases include a depth limitation? No....more

Federal Court Gives a Primer on Oil and Gas Lease Maintenance

In re: EP Energy E&P Company, LP considered three lease maintenance provisions in several oil and gas leases. The federal district court ruled that the leases were maintained in force after cessation of production despite...more

AAPL Has a Model Form Participation Agreement

Author Paul Yale* In the summer of 2022, the Executive Committee and Board of Directors of the American Association of Professional Landmen approved the first ever Model Form Participation Agreement to be approved by the...more

An Oil and Gas Receivership Ain’t Over ‘Til It’s Over

Remnant LLC v. Permico Royalties LLC, et al determined that a 90-year-old claim to ownership of a forfeited corporation was not valid. The players - Hoffman: By most accounts a scoundrel and con man who plied his...more

Texas Railroad Commission’s Denial of MIPA Forced-Pooling Affirmed

If you follow the Texas Railroad Commission closely, you should read Ammonite Oil & Gas v. Railroad Commission of Texas, in which the Supreme Court rejected a mineral owner’s effort to force pool an interest under the Mineral...more

Texas Surface Owner Denied the Right To Buried Pipeline

Unitex WI LLC v. CT Land and Cattle Company LLC rejected the surface owner’s effort to force the mineral lessee to bury a pipeline below plow depth. Surface owner CT’s claim was based on a mineral lease signed by former owner...more

Louisiana Supreme Court Issues Major Post-Production Cost Opinion

In Self v. BPX Operating, a case with significant implications for Louisiana operators and royalty owners, the Supreme Court of Louisiana ruled that the doctrine of negotiorum gestio in La. Civil Code art. 2292 does not allow...more

No Compound Interest on Unpaid Royalties Under Texas Oil and Gas Lease

It’s not exactly Deuteronomy 23:19, but the Supreme Court of Texas has an opinion about interest. They don’t like it if it’s compounded. Samson Exploration LLC v. Bordages addressed interest to be charged on unpaid royalties...more

How Courts Look at Fixed or Floating Royalty Disputes

Montgomery Trustee v. ES3 Minerals and Echo Minerals is another Texas fixed or floating royalty case. Before diving into the details, perhaps it’s best to describe the pattern the courts seem to fall into to resolve these...more

Supreme Court of Texas Sorts Out Complicated Assignment of Oil and Gas Leases

In Occidental Permian, Ltd. et al v. Citation 2002 Investment LLC  the Supreme Court construed a 1987 assignment from Shell Western E& P Inc. to Citation of a large number of properties. The instrument contained these...more

Supreme Court of Texas Decides Another Post-Production Cost Dispute

In Carl v. Hillcorp Energy the Supreme Court of Texas addressed the relationship between the lessee’s use of gas off-premises under a free-use clause and the lessor’s burden to share post-production costs (PPCs) under the...more

Fraud in an Oil Deal Revealed after Nine Years

In the Estate of Larry Wayne Ewers is a reminder of a few guidelines for oil and gas investing:   Think twice before giving money to your scripture-spouting friend from church....more

Louisiana Regulatory Taking Claim Defeated

Itching to sue the government for taking your property? Treme v. St. John the Baptist Parish Council is a reminder that you must have a property interest subject to being taken in order to have standing to sue for a...more

Mineral Lessee’s H2S Damage Claim Rejected

Landowner and mineral owner (that includes you, lessee): Under ETC Texas Pipeline, Ltd. v. Ageron Energy, LLC, your right to sue for damages for tort or trespass could pass into history before you even know you have a claim....more

Is a Merger a “Transfer of Leases”?

In Texas, no. Read on to learn why. In Nortex Minerals LP v. Blackbeard Operating LLC et al, the question was the meaning of this limited assignment provision in the “Alliance Leases”, oil and gas leases covering 27,000 acres...more

Texas Court Considers Trespass by Produced Water Injection – Part 2

See yesterday’s post on Iskandia Operating, LLC v. SWEPI, LP - SWEPI’s motion for summary judgment alleged that Iskandia presented no evidence of one or more elements of its trespass claim, noting that the Supreme Court of...more

Agreed Judgment and Division Order Don’t Avoid Double Royalty Payment

So, you found all the heirs and you have an agreed judgment stipulating title. Time to pay royslties? Maybe. And you have signed division orders. Surely, you can pay now? Maybe. These were the questions facing the parties in...more

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

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

Fifth Circuit Punts Postproduction Cost Question to Louisiana Supreme Court

The question in Self v, BPX Operating Company is how to balance the Louisiana Civil Code Art 2292 principle of negotiorum gestio against Louisiana’s conservation statutes....more

Lessee: Don’t Covet Your Neighbor’s Operations

Can the Texas lessee perpetuate his oil and gas lease by “constructive participation” in wells drilled by another? Under the facts in Cromwell v. Anadarko E&P Onshore, LLC, the answer is no....more

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