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Operator Excused from Texas Relinquishment Act Claims

In Williams O & G Resources, LLC v. Diamondback Energy, Inc., a federal magistrate judge concluded that the Texas Relinquishment Act does not apply to public-school lands patented after 1931. The report and recommendation was...more

Texas Pore Space Ownership – Royalty Calculation

In Myers-Woodward, LLC v. Underground Services Markham, LLC et al, (discussed previously) the parties disagreed on how to calculate Myers’ royalty on salt produced by Underground....more

Who Owns the Subsurface Pore Space in Texas?

In a word, the surface estate owner. If that’s all the learning you are up for today, proceed directly to the musical interludes. If you want to know why the Supreme Court of Texas had to say this again, read on....more

Bad Guys in Energy Paid the Piper in 2024

As in every year, in 2024 the grinches of law enforcement brought financial and corporal misery to bad guys in energy. Here is a review of the crimes of only a few of the convicted, admitted and alleged bribsters, swindlers...more

Uri Force Majeure Cases Still Percolating

Thought you’d heard the last of force majuere cases arising from Winter Storm Uri? Think again. In Marathon Oil Company v. Koch Services LLC. the question was how to measure damages suffered by Koch for Marathon’s...more

Bankruptcy Court Blocks GLO’s State Lease Termination

In In re Pearl Resources LLC, a Houston bankruptcy court rejected the Texas General Land Office’s attempt to partially terminate state oil and gas leases in Pecos County, despite finding the operator had breached offset well...more

Geophysicist’s Claims Turn on Definitions

Sewak v. Sutherland Energy Co. Ltd. is of interest for how the court defined terms commonly used in consulting contracts in the oil and gas industry, and how difficult it is to foresee all contingencies when negotiating a...more

What’s the Difference Between a Mineral Reservation and an Exception?

The category is “terms that confuse us” for one hundred dollars. Without resorting to your favorite legal dictionary or lawyer, explain the difference between a reservation and an exception in a Texas warranty deed. Stumped?...more

Texas Court Shields Severed Mineral Interests from Tax Foreclosure Judgment

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

Texas Court Extends Statutory Waste Provisions to Disposal Wells

We begin with a word from your sponsor. After enduring several generative AI tutorials, we urge you to keep on reading Energy and the Law. Why? Our blog is more accurate, at least a little “fun”, offers insightful musical...more

Marcel Exception to Louisiana Oilfield Anti-Indemnity Act Clarified

An understanding of Willis v. Barry Graham Oil Service LLC requires knowledge of two principles underlying the Louisiana Anti-Oilfield Indemnity Act: The LOAIA bars an oilfield agreement to the extent that the agreement...more

Texas Court Limits Tortious Interference Claims in Oil & Gas Assignment Dispute

The growling and barking presented by a claim for tortious interference is often far worse than the bite. Consider Segundo Navarro Drilling, Ltd. v. Chilton , which is a good example of that phenomenon in an oil and gas...more

How Does the Model Form JOA Address an Operator/Non-Operator Dispute?

Texas Crude v. Burlington Resources Oil and Gas considers the relationship between the operator and non-operators under Articles V and VI of the 1982 Model Form Joint Operating Agreement....more

Texas Supreme Court Allows Enforcement of a JOA Debt After Foreclosure

In Steelhead Midstream Partners, LLC v. CL III Funding Holding Company, LLC, the Texas Supreme Court authorized a pipeline owner’s breach-of-contract claim—alleging a co-owner used foreclosure to avoid cost-sharing...more

Scribner’s Error: A Cautionary Tale of Oil & Gas Fraud

DALF Energy, LLC v. GS Oilfield Services addresses a fiduciary’s deceptive actions in oil and gas transactions. The Fifth Circuit held: self-dealing may constitute a breach of fiduciary duty even when the principal is...more

Texas Mineral Buyer’s Due Diligence Falls Short

Patch LLC et al v. Indio Minerals LLC et al  was a dispute over title to a 1/8th NPRI in land in Midland County. Viola Ash, an Illinois resident, executed a warranty deed in 1932 for land in Midland County, reserving a 1/8...more

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

How to Work for Free Under a Master Service Agreement

Kouatli v. Endeavor Energy Resources L.P. offers valuable (and obvious) lessons on how NOT to perform a Master Service Agreement in the oil patch (or, per Billly Bob and friends, “The Patch”), to wit...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

What Will the Texas Supreme Court Say About Allocation and PSA Wells?

Alas, we might never know. Opiela v. Railroad Commission of Texas and Magnolia Oil & Gas Operating, was a challenge to the Commission’s authority to issue permits for allocation wells and wells drilled under Production...more

Arbitration Result Can Be “Good”, “Bad” or “Ugly”

The message in RSM Production Corporation v. Gaz du Cameroun SA: According to the federal Fifth Circuit, an arbitration tribunal’s construction of a contract and the arbitration rules governing the dispute “hold, however...more

Louisiana Oilfield Anti-Indemnity Act Nullifies an Indemnity Obligation

In In the Matter of Offshore Oil Services, Inc., Offshore owned and operated the M/V Anna. Offshore sued Island Operating Company for exoneration and/or limitation of liability for a personal injury claim by an employee of...more

Definitions Mattered in Oil Field Master Services Agreements

MDC Enegy LLC v. Crosby Energy Services Inc. et al. was an indemnity dispute in which the players were many and the facts complicated. But first...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

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