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A 1950 Deed Creates Title Chaos

Karli v. Wilson instructs mineral/royalty traders and their scriveners on a surefire way to create title chaos out of what could have been an uncomplicated land transaction. In 1950 the Wilson siblings and spouses executed a...more

Lessors’ Numerous Claims Against Operator Thwarted

For an example of a case gone wrong in so many ways, look no further than Evans Resources LP et al v. Diamondback E & P. - The facts...more

Texas Business Court Addresses Another Winter Storm URI Force Majeure Dispute

In Marathon Oil Co. v. Mercuria Energy America, LLC, the Texas Business Court (11th Division) considered a North American Energy Standards Board (NAESB) contract to buy and sell natural gas. With three opinions to discuss,...more

Beware When Buying Minerals After a Tax Suit Foreclosure

White Star Energy Inc. v. Ridgefield Permian Minerals, LLC is yet another title dispute reiterating that buying minerals that were once the subject of a tax suit foreclosure is fraught with uncertainty regardless of who you...more

Texas Court Denies Surface Owner's Self-Help Burial of Pipeline

In Byrne Oil Co. v. Walraven, a court of appeals held that a surface owner/lessor cannot bury his lessee’s pipelines and recover costs when adequate time exists to pursue judicial remedies, even after years of operator delay....more

Not the Same Property Means Not the Same Subject Matter – Res Judicata Defense Denied

Lula Eades once owned minerals in Loving County, Texas. In 2000, in a single lawsuit the Wink-Loving ISD and Loving County foreclosed on the mineral and royalty interests of more than 80 owners, including Lula. In Ridgefield...more

Passage of Time and Lack of Commissioners' Authority Bar Road-Access Claims

Once again, a Texas court has barred a lawsuit because the plaintiff waited too long to file. And once again, perhaps, the suit was a Hail Mary after alternatives failed. In Hobson v. Commissioners Court of Palo Pinto...more

“All” Really Means “All” in Texas: Court Affirms Broad Assignments Despite Ambiguous Exhibits

Ambiguity is handy for office-seekers intending to walk back “promises” they later say they really didn’t make. It doesn’t work so well for the stability of land titles. In Thagard Mineral Partnership, LP v. Cass v. RIM, LLP,...more

Louisiana Oilfield Anti-Indemnity Act Nullifies Offshore Indemnity Obligation

You would think that a Master Service Contract concerning boats and oilfield operations in the Gulf of Mexico would be governed by federal maritime law. In some situations you would be mistaken, says Offshore Oil Services,...more

What’s New in the Climate Wars?

Some things aren’t. In keeping with its familiar journalistic standards, the New York Times presents fact-free opinion in a place (page 1, top of the fold) usually reserved for news, this time in its July 26-27 International...more

Texas Venue Selection Statute Requires $1 Million on Its Face to be a Major Transaction

Defendants – five oil and gas operators – challenged a venue selection clause requiring that suits be filed in Nueces County for disputes over La Salle County acreage. In In re INEOS USA Oil & Gas LLC, a Texas Court of...more

Tracing Fails to Establish that Texas Mineral Interests Were Separate Property

O’Connor v. O’Connor addresses tracing of property in a divorce proceeding and an evidentiary issue, but there are lessons for parties to mineral deeds as well. First, … A few Texas marital property rules - Property...more

Department of the Interior Fails to Give Fair Notice of its Administrative Action

If you are the type to be preoccupied with the drudgery nuances of federal statutory and regulatory interpretation, or if you have a fetish for acronyms, I recommend that you read all 41 spellbinding pages of W&T Offshore v....more

Texas Royalty Owner Bears Postproduction Costs on Gas Sold at the Wellhead

City of Crowley v. TotalEnergies E&P USA, is a post-production cost (PPC) case with a predictable result. The Fort Worth Court of Appeals confirmed its reasoning in Shirlaine W. Props. Ltd. v. Jamestown Res., L.L.C from 2021,...more

Oral Promises, Paper Truths in a Texas Mineral Transaction

The Texas Supreme Court in Roxo Energy Company, LLC v. Baxsto, LLC reinforced a fundamental contract principle: when fully integrated agreements plainly conflict with prior oral representations, reliance on those inconsistent...more

Texas Court Splits Family Timber Land Over Heir’s Objections

“He who comes for the inheritance is often made to pay for the funeral”.* When heirs inherit property together and can’t agree on its use, Texas courts strongly prefer dividing the land physically rather than forcing a sale,...more

A Lesson on How Not to Recover an NPRI in Texas

It seems to be fairly well settled that you can’t use trespass-to-try-title to recover a nonpossessory royalty interest in Texas. What if you call the interest a “mineral interest stripped of every attribute except the right...more

Limitations and Standing to Sue Dry Up Landowners’ Claim to Texas Riverbed

State of Texas. V. Reimer et al. studied lawyer-nerdy questions of standing to bring a lawsuit and statutes of limitations as applied to inverse condemnation suits.  Spoiler alert: To the chagrin of the landowners, waiting...more

Another Louisiana Post-production Cost Case … and More

Dow Construction, LLC v. BPX Operating Company resolved a bundle of issues arising out of a drilling unit established by the Louisiana Commissioner of Conservation: who has the right to a drilling cost report, the operator’s...more

It’s Been Decided, In Texas the Mineral Lessee, Not the Surface Owner, Owns Produced Water

In Cactus Water v. COG Operating, the Supreme Court affirmed that mineral lessee COG, not water rights owner Cactus (who derived it rights from the surface owner), has the right to possession, custody, control, and...more

Ambiguity Frees Louisiana Royalty Owner From Post-Production Costs

In Franklin v. Regions Bank the Fifth Circuit concluded that a royalty clause in a mineral lease resulted in a gross proceeds royalty; the royalty owners did not bear their proportionate share of post-production costs. Read...more

How Did the 2025 Texas Legislature Address Energy?

Your Legislature has adjourned after enacting significant bills affecting the energy industry. To sum it up, the industry has friends in high places whenever the Lege is in session (Alternative energy was in jeopardy for a...more

Texas Operator Protected From Royalty Payment Error

The takeaway from DDR Weinert, Limited et al v. Ovintiv USA Inc. is that equitable recoupment rescued a royalty payor from its mistaken payment of royalties. But first, The events. The Richters were mineral lessors...more

Two Words = Six Million Dollars: SCOTX Reverses Trial Court That Added Words to a Gas Transportation Agreement

In American Midstream (Alabama Intrastate), LLC v. Rainbow Energy Marketing Corporation, the Texas Supreme Court held that the trial court improperly inserted the words “scheduled” and “physical” into a contract. By...more

Texas Supreme Court Decides Who Must Produce to Maintain an Oil and Gas Lease

In Cromwell v. Anadarko E & P Onshore LLC the Supreme Court of Texas did what it so often does: In order to provide “legal certainty and predictability”, the Court considered the plain language of a contract in order to...more

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