Ohio Supreme Court Joins Texas and Oklahoma in Holding the State Does Not Recognize a Separate Implied Covenant to Explore Further -
"We conclude that Ohio does not recognize an 'implied covenant to explore further' separate and apart from the implied covenant of reasonable development."
Why this is important: Landowners held interests in approximately 74 acres of land in Washington County, Ohio, not far from the Ohio River. The land was subject to a 1980 oil and gas lease. In return for permission to mine the land, the company committed to making royalty payments based upon the amount of gas produced from the land and to deliver a portion of the oil produced from the land to the lessors. The lease was silent as to certain drilling aspects....
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