News & Analysis as of

Mineral Rights

Husch Blackwell LLP

Balancing Old and New: Developing Renewable Energy Projects and Data Centers on Oil and Gas Sites

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Texas has been the top oil and gas producing state in the country since at least the 1970s, today contributing 42% of the nation’s crude oil and 27% of its natural gas. Now, the Lone Star State is also experiencing a boom in...more

Oliva Gibbs LLP

Reservation or Limitation on Warranty? Navigating the Fine Line — Lessons from Valence Operating Co. v. Davidson

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In Valence Operating Co. v. Davidson1, the Court of Appeals for the Sixth Appellate District of Texas at Texarkana addressed whether the provision, “all Oil, Gas and other Minerals have been excepted and reserved by former...more

Vorys, Sater, Seymour and Pease LLP

Supreme Court of Ohio Dismisses Appeal Seeking to End Senterra’s “Rolling Analysis”

In Senterra Ltd. v. Winland, 2019-Ohio-4387, Ohio’s Seventh District Court of Appeals held that an examiner, after identifying the root of title and finding that an exception to marketable record title applies, should review...more

Gray Reed

Texas Court Shields Severed Mineral Interests from Tax Foreclosure Judgment

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In Bush v. Yarborough Oil & Gas, LP a decades-old tax foreclosure judgment did not affect a previously severed mineral interest not owned by the delinquent taxpayer. The mineral owners were neither named nor served in the...more

Houston Harbaugh, P.C.

Ohio Appeals Court Rules that Horizontal Shale Well Was “On” the Leased Premises

Houston Harbaugh, P.C. on

Let’s assume you own a 175 acre farm in Washington County. Your grandfather acquired the farm back in 1948 from Farmer Brown (the “1948 Deed”). Your grandfather always said that he bought both the surface and oil and gas. In...more

Gray Reed

Ratifications, Stipulations, and Fixed vs. Floating Royalty Interests

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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

Gray Reed

Timing Matters: Deadlines for Filing a Texas Mineral Lien Under Chapter 56

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Not all liens are created equal. The most commonly discussed lien is related to construction improvements under Chapter 53 of the Texas Property Code. For those in the oil & gas/energy segment lien rights exist under Chapter...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

Louisiana Operator Survives Forfeiture of Right to Recover Drilling Costs

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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

Gray Reed

Choice of Words Matters in an Override Assignment

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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

Gray Reed

Federal Court Gives a Primer on Oil and Gas Lease Maintenance

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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

Oliva Gibbs LLP

“After Acquired Title” to Remain a Caged-Bird after Dellit v. Schleder, 2022 MT 196, 518 P.3d 830

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Introduction - “No one has a vested interest in any rule of common law.” Meech v. Hillhaven W., 776 P.2d 488, 494 (Mont. 1989). Luckily the Montana legislature has codified the common law rule of after-acquired title as a...more

Oliva Gibbs LLP

No Standing, No Sale: What Cardinal Minerals, LLC v. Miller Means for Ohio Mineral Transactions

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Who has standing to challenge abandonment of a mineral interest under the Ohio Dormant Mineral Act (“DMA”)? Earlier this year in two cases, both styled Cardinal Minerals, LLC v. Miller, the 7th District Court of Appeals of...more

Gray Reed

“Free of Cost” Royalty Includes Post-production Costs

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Fasken Ranch Ltd et al v. Puig et al featured a reservation in the sale of a ranch of an undivided 1/16 non-participating royalty interest “free of cost forever.”  What does that mean? In particular, does it mean that the...more

Houston Harbaugh, P.C.

Buyers and Sellers of Pennsylvania Real Estate Should Use Caution

Houston Harbaugh, P.C. on

If you have bought or sold property in Pennsylvania, you have likely encountered the Oil, Gas and/or Mineral Rights/Interests Disclosure© form prepared by the Pennsylvania Association of Realtors as part of the sales...more

Houston Harbaugh, P.C.

Landowners Should Ensure that Solar Farm Payments Retain Their Value Over Time

Houston Harbaugh, P.C. on

Leases for solar energy facilities offer property owners the potential for a predictable, long-term revenue stream. But, because of the potential decades-long duration of a lease for solar energy facilities, things like...more

Houston Harbaugh, P.C.

Texas Appeals Court Rules that Surface Owner Could Not Enforce Pipeline Burial Covenant in Oil and Gas Lease

Houston Harbaugh, P.C. on

Let’s assume that you purchase a 105 acre farm in Greene County in 2022. You purchase only the surface estate while the seller, Farmer Jones, retains the underlying oil and gas rights. You intend to grow corn and winter...more

Gray Reed

Louisiana Supreme Court Issues Major Post-Production Cost Opinion

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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

Gray Reed

Wind Farm Ejected from Osage Land

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In United States v. Osage Wind LLC a federal court in Oklahoma awarded permanent injunctive relief against a developer in the form of ejectment of a wind turbine farm after finding a continuing trespass....more

Houston Harbaugh, P.C.

Texas Supreme Court Addresses Fuel Gas Question

Many oil and gas leases across Pennsylvania allow the driller to divert and use volumes of raw gas to power and fuel production operations both on and off the leasehold. Is a driller obligated to pay a royalty on that volume...more

Gray Reed

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

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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

Oliva Gibbs LLP

Making Your Words Count

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A recent decision by the Fourth Court of Appeals reiterates the Texas judiciary’s commitment to interpreting the four corners of a document where language is unambiguous, and to giving plain and ordinary meaning to the...more

Gray Reed

Supreme Court of Texas Decides Another Post-Production Cost Dispute

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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

Gray Reed

Fraud in an Oil Deal Revealed after Nine Years

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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

DarrowEverett LLP

Betting the Farm on Solar: Leasing and Due Diligence Considerations

DarrowEverett LLP on

While imagery of the American Dream used to be picturesque farm towns, robust bounties and families gathered around the table for a meal, values have shifted, and once-robust farming communities have become forgotten lands,...more

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