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Market Value at the Well Trumps Free-Use Clause

The common thread throughout the myriad oil and gas royalty cases decided recently by Texas courts could be “harmony”, the reading of different, seemingly conflicting, contract provisions so as to give meaning to all....more

Beware Assignor: Own the Leases Before You Reserve the Override

Let’s begin with a quiz. Armour purchases non-recourse mortgage notes, becoming a lienholder in 99 oil and gas leases and 13 wells; fails to record the transfer documents in the real property records; assigns the leases to...more

City of Dallas Owes $33+ Million for Drilling Permit Denials

If you have ever wondered how many ways a cocktail of stupidity*, treachery and feckless government can inflict financial harm on the undeserving, including the citizens the feckless government leaders are supposed to serve,...more

Arbitration Over Offshore Leases Does Not Warrant Lawsuit Dismissal

Just because parties agree that disputes over a contract will be subject to binding arbitration doesn’t mean there won’t be wrestling at the courthouse beforehand. In LLOG Exploration Offshore, LLC v. Samson Contour Energy...more

Texas Correction Deed Statute Revisited … Again

You might recall this post on Broadway National Bank, Trustee v. Yates Energy Corporation. We now have Yates Energy Corporation et al v. Broadway National Bank, Trustee, the court of appeals’ ruling after remand. Recall the...more

Busted Land Transaction Violated the Statute of Frauds

In the Estate of Terry Banta presents yet another purported Texas land transaction doomed because of disregard for the Statute of Frauds. Terry Banta and the Herriotts entered into an oral agreement for the Herriotts to...more

Texas Correction Deed Statute Revisited

Those who continue to be horrified by Broadway National Bank, Trustee v. Yates Energy Corp. should be relieved that the result in Endeavor Energy Resources, LP v. Anderson was more equitable. In Yates, the Texas Supreme Court...more

Texas Court Addresses MSA Indemnity Obligations

At issue in RKI Exploration and Production LLC v. AmeriFlow Energy Services LLC and Crescent Services, LLC. were two Master Service Agreements.  RKI was the operator of a well in Loving County; AmeriFlow and Crescent were...more

Court Finds Declaratory Judgment Action, Not Trespass to Try Title

SM Energy Co. v. Union Pac. R.R. Co. considers a question frequently asked in Texas suits affecting title: When is a suit a trespass to try title action and not a declaratory judgment action?...more

Exculpatory Clause Does Not Save Operator From Liability

Non-operators under the 1989 Model Form JOA have been hoping to drive a stake through the dark heart of Reeder v. Wood County Energy, LLC. Bachtell Enterprises, LLC v. Ankor E&P Holdings Corp might be a start. The question...more

Were the Mineral Deeds a Gift or a Sale? It Made a Difference.

The question presented in Aaron v. Fisher et al: Did mineral deeds bestow separate property upon the grantees by gift, or did they convey a community property interest to the grantees and their spouses by sale for...more

Royalty Obligations on Free-Use Gas Redux

Recall our recent post on Carl v. Hilcorp Energy Company from the U.S. District Court for the Southern District of Texas discussing the lessee’s royalty obligations on gas used off the premises in a market-value lease. See...more

No Off-Lease Gas Use Recovery For Royalty Owners

The question is presented again but in a different format: In Texas is a lessee allowed to deduct post-production costs (PPC’s) from the lessor’s gas royalty? In Carl v. Hilcorp, the answer was “yes” based on the language in...more

Clause to Protect Against Drainage in a Mineral Lease Deemed Ambiguous

Today we will skip our usual routine of explaining how court rulings on the question of the day might affect your interests. Instead we will discuss the fallout from abysmal document drafting. In Rosetta Resources Operating...more

Lease Perpetuated Beyond Primary Term Without Production in Paying Quantities

If perpetuation of a mineral lease beyond the primary term is contingent upon continuous operations, do traditional notions of “production in paying quantities” always matter? Spoiler: No....more

Texas Mineral Deed Signed Away Right to Sue

The question in litigation is usually “WHAT”: what happened, what contract was breached, what did someone do or fail to do, and so on. In Hughes v. CJM Resources, LP, the question was, “WHO” had the right to file the suit in...more

Most-Favored-Nations Clause Costs Lessee

This “most-favored-nations” clause in three oil and gas leases on land in LaSalle County, Texas, was at issue in EP Energy E&P Co., L.P. v. Storey Minerals, Ltd. ...more

The Meaning of “Subject To” in a Deed

Commonwealth of Pennsylvania v. International Development Corporation resolved the question, In a 100 year old Pennsylvania deed is a “subject to” provision an exception to a grant or a warranty disclaimer?...more

A Texas Lien is Invalid if the Mineral Owner is Not Yet Obligated to Pay

A subcontractor’s mineral lien in Texas is invalid when, at the time the mineral owner receives notice of the lien affidavit, the mineral owner is not yet obligated to pay the contract price to its contractor.  So says Pearl...more

Texas Supreme Court Clarifies Postproduction Cost Decision

It was jurisprudential Groundhog Day as the Supreme Court of Texas handed down Nettye Engler Energy v. Bluestone Natural Resources, another in a series of postproduction cost disputes, only two days after Puxsutawney Phil...more

Texas Court Decides What “Likewise” Means in a Conveyance

Consider the power of a single word over the fortunes of the parties to a property deed. Such was the court’s analysis in Barrow Shaver Resources, LLC, et al v. NETX Acquisitions, LLC, et al....more

Louisiana Court Considers Texas and Louisiana Oilfield Anti-Indemnity Acts

Federal Insurance Company et al v. Select Energy Services LLC and Exco et al. is a reminder for negotiators of indemnity and defense obligations in oilfield contracts that choice of law is important. Ignore it when drafting...more

Buried Pipeline Ruling Favors Lessors

In Texas, what happens to an obligation to bury pipelines when, after creation of the obligation, the surface and minerals are severed?  Henry v. Smith explains....more

Texas Supreme Court to Review the Lessee’s Covenant to Protect Against Drainage

First, a word for you scriveners: Preserve your reputation and the honor of your law school writing instructor by preparing clear and understandable contracts. ...more

Texas Court Accepts Only One Meaning of “Leased Premises” in an Oil and Gas Lease

How many different meanings can parties attribute to a term in an oil and gas lease?  Answer: As many as they want, but the court will only use one, says King Operating et al v. Double Eagle Andrews, LLC et al....more

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