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Another Post-Production Cost Decision in Texas

In resolving a dispute over post-production cost deductions from oil and gas royalties (PPC’s), the court in Shirlaine West Properties Ltd et al v. Jamestown Resources, LLC and Total E&P USA, Inc. opined that the case ” … is...more

Addendum Prevails over Form … Again

When the form contract says one thing and the addendum says another, which one would you expect to prevail?...more

Louisiana Court Considers Buried and Surface Flowlines

In Emerald Land Corp. v. Trimont Energy (BL) LLC, a Louisiana federal court considered whether a lessee was required to remove flowlines buried beneath the surface and canal bottoms of property subject to mineral leases....more

Statute of Frauds Torpedoes an Overriding Royalty Sale

Here we go  again, in Gary and Theresa Poenisch Family Ltd. P’Ship v. TMH Land Servs., Inc., learning that a purported Texas land transaction will not be enforced if the parties fail to comply with the Statute of Frauds....more

Added Party Can’t Avoid Amended Master Service Agreement

Let’s begin with a question: Master service agreements (“MSA’s” in the trade), once agreed upon, often remain in force for years. As time passes and circumstances change, the parties amend, sometimes losing sight of the...more

Texas Court Rules on a Retained Acreage Clause

Sometimes writing too many alternatives into an oil and gas lease invites confusion … which provokes litigation … which results in disappointment for somebody … or everybody. ...more

Lessor Prevails in Texas Lease Termination Dispute

Lollygag: To fool around and waste time; dawdle.  As in, “I lollygagged for 15 years after filing my suit and obtained a less-than-optimal result.”...more

Texas Court Addresses Anti-Washout Clause and Rule Against Perpetuities

Yowell v. Granite Op. Co. and Apache Corp. v. Peyton Royalties, L.P. is another Rule Against Perpetuities case. Keep reading. The anti-washout protection for your reserved overriding royalty could be at risk....more

Texas Court Re-iterates the Need For Clearly Defined Contract Terms

In Apollo Exploration, LLC v. Apache Corp., Texas’ 11th Court of Appeals analyzed several provisions of purchase and sale agreements in a complex oil and gas transaction and demonstrated a measured, text-centered approach to...more

Texas Court Applies Amended Citizens Participation Act to a Lease Dispute

Howard, et al. v. Matterhorn Energy, LLC, et al. [6th Dist.] May 4, 2021 considered the Texas Citizens Participation Act as amended, effective on September 1, 2019....more

Tax Foreclosure on Royalty Did Not Include Possibility of Reverter

Ridgefield Permian, LLC, et al. v. Diamondback E & P LLC, et al. addresses the scope of a property interest foreclosed upon by a tax suit in Reeves County, Texas. In this post we will shortcut the complicated facts and...more

Oil and Gas Lease Addendum Supersedes Printed Form

In Apache Corp. v. Hill, et al.,  lessors prevailed in a lease construction dispute because of the court’s unsurprising conclusion that a typewritten addendum to oil and gas leases superseded conflicting provisions in the...more

Texas Supreme Court Rules on Correction Deeds in a Case of First Impression

What if you pay good money for a mineral interest and record the deed in the official public records, thereby securing your title? What if your predecessors-in-title decide among themselves they made a material mistake in a...more

Ambiguity Foils Right of Way Agreement

The central issue in the Texas case of Cook v. Cimarex Energy Co.: Did Cook grant Cimarex a right of way across Cook’s land to the location of two Cimarex wells. No he didn’t. Reversing the trial court, the court of appeals...more

Mother Hubbard Clause Saves a Property Deed

Bell v. Midway Petroleum Grp., L.P., 9th Dist.] Mar. 18, 2021 was a trespass to try title action, suit to quiet title for possession of a land, and a counterclaim for title by adverse possession. ...more

What are “Drilling Operations”?

As Humpty Dumpty would have said to Alice if he were Justice Dumpty of the Texas Supreme Court, the term means whatever the parties to an oil and gas lease say it means, neither more nor less. In Sundown Energy LP, et al. v....more

Well Operator Protected by the Model Form JOA

What is the standard of care imposed by the Model Form JOA on the well operator?  Crimson Exploration Op., Inc. v. BPX Op. Co. gives us the answer, and it is no surprise....more

Texas Court Parses Three Retained-Acreage Clauses – Part 2

Yesterday we discussed aspects of PPC Acquisition Co., LLC, et al. v. Delaware Basin Res., LLC, et al. Today we consider whether the retained-acreage clauses created a special limitation or a covenant and the relationship...more

Texas Court Parses Three Retained-Acreage Clauses – Part 1

PPC Acquisition Co., LLC, et al. v. Delaware Basin Res., LLC, et al. addressed retained acreage clauses in three separate oil and gas leases covering the same 640-acre tract in Reeves County, Texas....more

Texas Supreme Court Deems Continuous Development Clause Ambiguous

In Endeavor Energy Resources, L.P. v. Energen Resources Corp. et al. the Supreme Court of Texas construed a continuous development clause in an oil and gas lease covering 11,300 acres in Howard County. After the primary term,...more

Contaminated Butane and Propane Creates Fight Over General Terms and Conditions

Enterprise Products Operating v. Trafigura, A G. asks, Who should pay when a “black blob” that had “the stench of a skunk” was left behind after $27 million worth of an odorless product is delivered from a ship?...more

Another Real Estate Contract Succumbs to Indequate Property Description

Dayston v, LLC v. Brooke, voided a real estate contract because it failed to satisfy the Texas statute of frauds. Let’s see how the drafting mishap occured....more

Texas Court Evaluates Consent to Assign an Oil and Gas Lease

In Mayo Found. For Med. Educ. & Research v. BP Am. Prod. Co. a United States District Court considered the circumstances under which a lessor can withhold its consent to assign an oil and gas lease....more

Lessons from an Operating Agreement Dispute

Jatex Oil & Gas, L.P. v. Nadel & Gussman Permian, L.L.C. presents several teachable moments: The Texas Property Owner Rule does not allow a non-expert testify on matters requiring expert testimony....more

Company Man Wins MSA Dispute

Lessons from BEPCO, L.P. v. RMTDC Operations, LLC d/b/a Total Energy Services. Operator BEPCO hired TOTAL for drilling consultant services under an MSA and hired Latshaw Drilling to drill a well on federal land in New...more

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