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Texas Supreme Court Holds that References to “One-Eighth” in Old Oil and Gas Conveyances Presumptively Refer to the Entire Mineral Estate

The Energy Law

In the 1920s—the time the deed at issue was executed—lessors commonly reserved a one-eighth royalty interest when they executed oil and gas leases. In addition to the estate misconception theory, the Court analyzed the “legacy of the one-eighth royalty.” Dils Co. , 2d 904 (Tex. Dawkins , 483 S.W.3d

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Texas Supreme Court Update: TRO-X Lives to Fight Another Day in Contractual Dispute over Share of Income on Production from Equitable Interests

The Energy Law

18-0983, 2021 WL 1045723, at *1 (Tex. 19, 2021) (“ Eagle II ”). In Eagle II , TRO-X alleged that Eagle failed to pay TRO-X its share of income generated from production on the equitable interests. TRO-X sought money damages to remedy the alleged breach, not transfer of title of a share of the Interests. TRO-X, L.P. ,

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Who Owns the Empty Space? Texas Supreme Court Affirms Surface Ownership of Salt Caverns in Landmark Ruling

Producer's Edge

" In 2008, USM acquired from Texas Brine Company "all of [Texas Brine Company's] right, title and interest, in and to all of the salt and salt formations only" on the property. Second, the parties disagreed over how to calculate Myers's royalty. Anadarko E&P Onshore, LLC, 520 S.W.3d West, 508 S.W.2d

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Texas Supreme Court Update: TRO-X Lives to Fight Another Day in Contractual Dispute over Share of Income on Production from Equitable Interests

The Energy Law

18-0983, 2021 WL 1045723, at *1 (Tex. 19, 2021) (“ Eagle II ”). In Eagle II , TRO-X alleged that Eagle failed to pay TRO-X its share of income generated from production on the equitable interests. TRO-X sought money damages to remedy the alleged breach, not transfer of title of a share of the Interests. TRO-X, L.P. ,