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Merger Clause Defeats Claim to the Farmhouse

Barkley v. Connally, a “bet-the-farm” case if there ever was one, invokes the merger clause, a basic principle of contract law. Clients and lawyers: Read this analysis so as to avoid boundless grief and disappointment for...more

Lessee: Don’t Covet Your Neighbor’s Operations

Can the Texas lessee perpetuate his oil and gas lease by “constructive participation” in wells drilled by another? Under the facts in Cromwell v. Anadarko E&P Onshore, LLC, the answer is no....more

Winter Storm Uri – No Summary Judgment This Time

Unit Petroleum Company v. Koch Energy Services, LLC is another force majeure case arising out of winter storm Uri. Unlike a similar case, summary judgment was denied because, said the United States District Court, The word...more

Federal Court Distinguishes Devon v. Sheppard

Producers disappointed by the Supreme Court’s holding in Devon Energy Production v. Sheppard might have reason to feel vindicated. The question in HL Hawkins Jr., Inc. v. Capitan Energy Inc. et al. was whether producer...more

“Harmony” in a Texas Mineral Reservation

In Smart v. 3039 RNC Holdings LLC, the court reminds us that it will harmonize all parts of a contract, even one that “is not a model of clarity”, to reach the correct result. ...more

Supreme Court of Texas Tackles the Meaning of “Predecessors”

The plain, ordinary, and generally accepted meaning of a word doesn’t mean “anything goes”. It depends on context, says the Supreme Court of Texas in Finley Resources Inc. v.  Headington Royalty Inc., a dispute over the...more

Court of Appeals Rules on Texas PSA Well Permit

The Austin Court of Appeals has ruled in Texas Railroad Commission et al v. Opiela, the dispute over a permit for a horizontal well under a Production Sharing Agreement.  We reported on the result in the trial court. Here are...more

How to Lose Your Working Interest in 26 Annual Steps

Can a non-operating working interest in a Texas oil and gas lease be adversely possessed? The Amarillo Court of Appeals said yes in PBEX II, LLC v. Dorchester Minerals, L.P....more

JOA Cross-Netting Question Almost Answered

One of the questions raised in 1776 Energy Partners, LLC v. Marathon Oil EF, LLC was whether Marathon as operator could apply revenues owed to non-operator 1776 under one joint operating agreement to satisfy unpaid debts owed...more

Appeals Court Revives Lessor’s Fraud Claims

Tips on litigation avoidance: Not making promises you don’t intend to keep is easy enough. Stating a fact or making a promise and things change, you could be a fraudster if you don’t come clean before closing....more

Texas Supreme Court Rules on Suspension of Proceeds of Oil and Gas Production

Freeeport-McMoRan Oil and Gas, LLC and Ovintiv USA Inc. v. 1776 Energy Partners LLC  presented a recurring question faced by Texas oil and gas producers:  When can proceeds of production be withheld by the operator without...more

A Day Made a Difference in This Purchase and Sale Agreement

And what a difference it was! In Apache Corp. v. Apollo Expl. LLC et al, Apache and others acquired an oil and gas lease on 100,000+ acres in the Texas Panhandle. The primary term was three years. The effective date was...more

Insurance Coverage Not Limited by a Texas Service Agreement

As you negotiate your master service agreements are you confident that you know how insurance choices might affect indemnity obligations? Me neither. That’s why I turn to my Gray Reed partner Darin Brooks and his insurance...more

More Force Majeure Fallout From Uri

MIECO, LLC v. Pioneer Natural Resources presented a challenge to a force majeure defense in a dispute arising from Winter Storm Uri. The defense carried the day....more

“All Means All” in Construing an Assignment of Leases

In a recurring theme, harmony and the four-corners rule were front and center in Citation 2002 Inv. LLC et al v. Occidental Permian, Ltd. et al, a case of competing claims over the granting language in an assignment of oil...more

Texas Supreme Court Rules on “Bespoke” Add-Back Royalty Clause

In Devon Energy Production Company, LP et al v. Sheppard et al, the Supreme Court of Texas construed what it referred to as a “bespoke” and “highly unique” royalty clause in several oil and gas leases to prohibit the...more

Reserved Royalty Interest is “Floating”

Texas courts continue to address the “fixed or floating” non-participating royalty interest question. The El Paso Court of Appeals’ answer in Bridges v. Uhl et al. was floating, based on the language in that particular...more

Long-Running Texas Boundary Dispute Continues

Ellison v. Three Rivers Acquisition LLC et al., on remand from the Texas Supreme Court, is the third round of a boundary dispute between mineral lessees in Irion County.   For the history of Ms. Ellison’s odyssey from...more

An Asset is an “Asset” Whether or Not BOEM Consents

The negotiators and scriveners of the purchase and sale agreement in Matter of PetroQuest Energy, Incorporated would have been well served to have considered all the potential ramifications, however remote, flowing from the...more

Waiting Too Long to Sue For a Working Interest is a Loser

Delay in filing suit too often spells doom for the plaintiff, as we learn in Zadeck Succession et al v. Treme et al. Treme (as in the family collectively) claimed their father, Vandiver, was conveyed a 5% working...more

Texas NPRI Not Diminished by Pooling Ratification

The takeaway from Hahn v. ConocoPhillips Company is that in Texas a NPRI holder may not diminish his rights by ratifying pooling of an oil and gas lease unless there are provisions explicitly purporting to do so....more

Oops! Sellers Didn’t Read The Mineral Deed Before Signing

Precious little legal analysis is required to grasp the lesson from Springbok Royalty Partners v. Cook.  No mode or manner of legal gymnastics is likely to save parties from the legal effect of a contract they didn’t bother...more

The “Greatest Estate” Doctrine Impacts a Lease Assignment

Let’s begin with some Texas law on what a seller sells when he executes a deed: Generally, a Texas real property deed will confer upon the grantee the greatest estate as the terms of the instrument will permit. This...more

A Harsh Result From a Lopsided Indemnity Agreement

Wagner v. Exxon Mobil Corporation is an example of the misfortune that can befall the purchaser who assumes the burden of comprehensive, one-sided indemnity obligations. We will disregard evidentiary and other issues in this...more

A Texas Fight Over Competing Leases

Let’s proceed directly to the takeaways from Fort Apache Energy, Inc. v. Short OG III, Ltd., et al, a Southern District of Texas bankruptcy court opinion. (Gray Reed partners Jim Ormiston and David Leonard represented Short...more

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