Recently, the Texas Court of Appeals for the Ninth District at Beaumont issued two contrasting opinions which provide guidance for the application of the Texas Supreme Court's 2012 decision in Texas Rice Land Partners, Ltd. v. Denbury Green Pipeline-Texas LLC.

On May 23, 2013, the Court of Appeals for the Ninth District of Texas decided Crosstex NGL Pipeline, L.P. v. Reins Road Farms-1,Ltd., NO. 09-12-00563-CV affirming the lower court's denial of a temporary injunction to Crosstex NGL Pipeline, L.P. ("Crosstex")which was sought to prevent Reins Road Farms-1, Ltd. ("RRF") from interfering with its attempt to survey RRF's property prior to constructing a natural gas liquid ("NGL") pipeline.