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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 support of that notion, the Court cited the 1957 Texas Supreme Court case Garrett v. Dils Co. , 2d 904 (Tex. Dawkins , 483 S.W.3d Element Petroleum Props., 11-21-00103-CV (Tex.

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