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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construction dispute because of the court’s unsurprising conclusion that a typewritten addendum to oil and gas leases superseded conflicting provisions in the...more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

A Long-Running Dispute Over an Acquisition Agreement is Returned to the Trial Court

This is another chapter in the long-running dispute between Eagle Oil & Gas Co. and. TRO-X, L.P.  The litigation arises out of an agreement to acquire and sell oil and gas leases. Here, TRO-X alleges that Eagle failed to...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

Texas Supreme Court Weighs in on Post-Production Costs

The Supreme Court of Texas has ruled that oil and gas leases under consideration in BlueStone Natural Resources II, LLC v. Walker Murray Randle, et al. did not permit deduction of postproduction costs from sales proceeds...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 NPRI Burdened with Post-Production Costs

BlueStone Nat. Res. II, LLC v. Nettye Engler Energy, LP is another Texas case deciding whether language creating a nonparticipating royalty interest prohibited deduction of post-production costs. (Spoiler alert: it didn’t....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

My Operator is Making Money … Part 2, The Operator’s Response

The threat: You, the operator, are operating unprofitable wells where monthly costs exceed or barely equal revenues, making money on the fixed COPAS overhead charges. Your non-operators are going into the economic hole and...more

My Operator is Making Money on the Well and I’m Not. What Can I Do? Part 1.

With the plunge in commodity prices many formerly profitable wells are now in the red, and we don’t know for how long. This is causing non-operators to question the bona fides of the operations … and of the operator, and to...more

Lignite Lease Prevails Over Pipeline Easement

San Miguel Electric Coop is a Texas nonprofit electric cooperative that owns and operates a power plant that supplies electricity to 38 Texas counties. After a four-week absence, they return to these pages, this time in DCP...more

When is a “Gross Proceeds” Royalty not Paid on Gross Proceeds?

Devon Energy Prod. Co., et al. v. Sheppard, et al is your kind of case if you are in search of: - A roadmap for slicing and dicing royalty calculations in myriad ways, - Pretty good summaries of the Supreme Court’s...more

Partition Agreement Outweighs Coal Surface Destruction Test

In Wheeler et al v. San Miguel  Electric Cooperative, we learn – again – the difficulty in asserting a position in litigation that is contrary to the actual words in the agreement you are fighting over....more

“Construction” of a Well Pad Requires More than a Survey

In Evans Resources, L.P., et al. v. Diamondback E&P, LLC, two agreements left the terms “constructed” and “utilized” undefined. If the terms had been defined would the outcome have been different? Maybe. Should parties define...more

Lessons from an Override Assignment

Contract construction cases are fact-specific, but one can take lessons of general application from all of them. Here are the takeaways from Jones Energy, Inc. v. Pima Oil & Gas, L.L.C....more

What is “Oil or Gas” as Used in a Pipeline Easement?

In Texan Land & Cattle II, Ltd. v. ExxonMobil Pipeline Company a Texas court of appeals ruled that “oil or gas” is not limited to “crude petroleum,” but includes refined petroleum products gasoline and diesel....more

Limitations Title Not Precluded by Late Acknowledgment

Scribner v. Wineinger, et al. affirms that acquisition of a Texas oil and gas leasehold by limitations is not defeated if the adverse possessor’s acknowledgement of a claimant’s title comes too late....more

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