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Beware Assignor: Own the Leases Before You Reserve the Override

Let’s begin with a quiz. Armour purchases non-recourse mortgage notes, becoming a lienholder in 99 oil and gas leases and 13 wells; fails to record the transfer documents in the real property records; assigns the leases to...more

City of Dallas Owes $33+ Million for Drilling Permit Denials

If you have ever wondered how many ways a cocktail of stupidity*, treachery and feckless government can inflict financial harm on the undeserving, including the citizens the feckless government leaders are supposed to serve,...more

Arbitration Over Offshore Leases Does Not Warrant Lawsuit Dismissal

Just because parties agree that disputes over a contract will be subject to binding arbitration doesn’t mean there won’t be wrestling at the courthouse beforehand. In LLOG Exploration Offshore, LLC v. Samson Contour Energy...more

Texas Correction Deed Statute Revisited … Again

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

Texas Correction Deed Statute Revisited

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

Court Finds Declaratory Judgment Action, Not Trespass to Try Title

SM Energy Co. v. Union Pac. R.R. Co. considers a question frequently asked in Texas suits affecting title: When is a suit a trespass to try title action and not a declaratory judgment action?...more

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

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

Royalty Obligations on Free-Use Gas Redux

Recall our recent post on Carl v. Hilcorp Energy Company from the U.S. District Court for the Southern District of Texas discussing the lessee’s royalty obligations on gas used off the premises in a market-value lease. See...more

No Off-Lease Gas Use Recovery For Royalty Owners

The question is presented again but in a different format: In Texas is a lessee allowed to deduct post-production costs (PPC’s) from the lessor’s gas royalty? In Carl v. Hilcorp, the answer was “yes” based on the language in...more

Clause to Protect Against Drainage in a Mineral Lease Deemed Ambiguous

Today we will skip our usual routine of explaining how court rulings on the question of the day might affect your interests. Instead we will discuss the fallout from abysmal document drafting. In Rosetta Resources Operating...more

Lease Perpetuated Beyond Primary Term Without Production in Paying Quantities

If perpetuation of a mineral lease beyond the primary term is contingent upon continuous operations, do traditional notions of “production in paying quantities” always matter? Spoiler: No....more

Most-Favored-Nations Clause Costs Lessee

This “most-favored-nations” clause in three oil and gas leases on land in LaSalle County, Texas, was at issue in EP Energy E&P Co., L.P. v. Storey Minerals, Ltd. ...more

The Meaning of “Subject To” in a Deed

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

Ohio Landowners Burdened with Post-Production Costs

Zehentbauer Family Land, LP v. TotalEnergies E&P USA, Inc. is a story we’ve heard before: Royalty owners contend they are not getting a big enough slice of the hydrocarbon pie, which presents a question courts must answer:...more

Louisiana Unit Operators May Deduct Post-Production Costs from Unleased Mineral Owners

The question with wide-ranging implications for Louisiana operators and mineral owners in Johnson et al. v. Chesapeake Louisiana LP et al is whether unleased mineral owners in a drilling unit established by the Commissioner...more

Stray Cows and Oilfield Operations Do Not Play Well Together

Foote and Cypert v. Texcel Exploration and Decker determined that cattle loitering uninvited around a well and tank battery are trespassers, not licensees. How it happened - Foote arranged with Yates to graze 650 head...more

Texas Supreme Court Clarifies Postproduction Cost Decision

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

Texas Court Decides What “Likewise” Means in a Conveyance

Consider the power of a single word over the fortunes of the parties to a property deed. Such was the court’s analysis in Barrow Shaver Resources, LLC, et al v. NETX Acquisitions, LLC, et al....more

Buried Pipeline Ruling Favors Lessors

In Texas, what happens to an obligation to bury pipelines when, after creation of the obligation, the surface and minerals are severed?  Henry v. Smith explains....more

Texas Supreme Court to Review the Lessee’s Covenant to Protect Against Drainage

First, a word for you scriveners: Preserve your reputation and the honor of your law school writing instructor by preparing clear and understandable contracts. ...more

Texas Court Accepts Only One Meaning of “Leased Premises” in an Oil and Gas Lease

How many different meanings can parties attribute to a term in an oil and gas lease?  Answer: As many as they want, but the court will only use one, says King Operating et al v. Double Eagle Andrews, LLC et al....more

Another Post-Production Cost Decision in Texas

In resolving a dispute over post-production cost deductions from oil and gas royalties (PPC’s), the court in Shirlaine West Properties Ltd et al v. Jamestown Resources, LLC and Total E&P USA, Inc. opined that the case ” … is...more

Fair and Reasonable Offer Required Before Force-Pooling in Texas

Ammonite Oil and Gas Corporation v. Railroad Commission of Texas illustrates the difficulties faced by lessees attempting to force-pool a tract under the Mineral Interest Pooling Act.  In this case, the applicant Ammonite...more

Addendum Prevails over Form … Again

When the form contract says one thing and the addendum says another, which one would you expect to prevail?...more

Louisiana Court Considers Buried and Surface Flowlines

In Emerald Land Corp. v. Trimont Energy (BL) LLC, a Louisiana federal court considered whether a lessee was required to remove flowlines buried beneath the surface and canal bottoms of property subject to mineral leases....more

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