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Contract Interpretation Mineral Rights

Oliva Gibbs LLP

Reservation or Limitation on Warranty? Navigating the Fine Line — Lessons from Valence Operating Co. v. Davidson

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In Valence Operating Co. v. Davidson1, the Court of Appeals for the Sixth Appellate District of Texas at Texarkana addressed whether the provision, “all Oil, Gas and other Minerals have been excepted and reserved by former...more

Oliva Gibbs LLP

If the Lease Requires Notice, Then Provide Notice: Simple Enough?

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I. Background In the case of Kirkbride v. Antero Res. Corp., the Sixth Circuit Court of Appeals is faced with a novel argument on the interpretation of a condition precedent within an oil and gas lease. The case comes to the...more

Gray Reed

“Harmony” in a Texas Mineral Reservation

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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

Gray Reed

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

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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

Gray Reed

Texas Correction Deed Statute Revisited

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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

Gray Reed

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

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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

Gray Reed

Texas Court Rules on a Retained Acreage Clause

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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

Gray Reed

Oil and Gas Lease Addendum Supersedes Printed Form

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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

Gray Reed

Texas Court Parses Three Retained-Acreage Clauses – Part 2

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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

Gray Reed

Texas Court Evaluates Consent to Assign an Oil and Gas Lease

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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

Gray Reed

Texas Supreme Court to Consider Continuous Development Clause

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The Texas Supreme Court has agreed to hear oral arguments in a dispute over an “accumulation” provision in a continuous development clause of an oil and gas lease.  The case is Endeavor Energy Resources L.P. v. Energen...more

Gray Reed

Fake Mineral Leases Thwarted by the Texas Legislature

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The 2019 Texas legislature enacted a new Property Code Section 5.152 to protect mineral and royalty owners from a certain species of fraudulent transactions perpetrated on trusting and/or naïve and/or out of state mineral...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Oil and Gas Lease: Texas Supreme Court Addresses Offset Provision

The Texas Supreme Court (“Court”) recently ruled in favor of Murphy Exploration & Production Company—USA (“Murphy”) in a dispute arising from the location of an offset well on the properties of Shirley Mae Herbst Adams and...more

Gray Reed

Ask and You Shall (Not?) Receive: Retained Acreage Clauses and the Texas Supreme Court

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Two Texas Supreme Court decisions published on the same day confirm that retained acreage clauses that vary in language from one instrument to another will likely vary in effect. Depending on the language, the lessee might...more

Porter Hedges LLP

Business Litigation Alert: "Texas Supreme Court Ruling Highlights the Importance of Heeding 'Red Flags' During Pre-Contract...

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Last month, the Texas Supreme Court upheld a lower court’s decision to toss a lawsuit by Orca Assets GP LLP against JP Morgan Chase over property in the Eagle Ford Shale. ...more

Gray Reed

NPRI Reservation Survives Rule Against Perpetuities

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Recall the Battle of the Bastards: The heroic Lady Sansa and the duplicitous Lord Baelish gallop over the hill to save the foolish Jon Snow from the heinous Ramsey Bolton. In similar fashion, but without the malnourished...more

Gray Reed

Fraud Claim Rejected for Unreasonable Reliance

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The ruling from the Supreme Court of Texas in JP Morgan Chase Bank, N.A., et al v. Orca Assets, G.P., L.L.C. was foreseeable. Experienced energy professionals who pass on the opportunity to examine title for themselves are...more

Gray Reed

Opinions to Expect From the Texas Supreme Court

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The Texas Supreme Court recently heard oral argument in three intriguing oil and gas cases. Here’s what you need to know about two of them (We’ll address the third case soon)....more

Gray Reed

A Partition Deed Fails in Texas

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Cases like Hahn v. Gips et al are like eating your broccoli – not so tasty but lots of fiber. The “fiber” here is the effect of a partition deed in which not all the cotenants join....more

Gray Reed

Louisiana Partition Agreement: You Can’t Trade What You Don’t Own

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Square Mile Energy LLC v. Pommier considered this language in a Louisiana partition agreement: “N.B: Included in this transfer are any and all mineral rights, when available, to Roxanne and all surface rights.” Did this...more

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