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
MARCH 7, 2023
According to the Court, the estate-misconception theory was so prevalent in instruments in and around 1924—the time of the deed at issue—that “courts have taken judicial notice of this widespread phenomenon.” Element Petroleum Props., Texas courts refer to this phenomenon as the “estate-misconception” theory. Dawkins , 483 S.W.3d
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