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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

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.” In support of that notion, the Court cited the 1957 Texas Supreme Court case Garrett v. Eastland June 1, 2021).

Royalty 98
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Harmonizing Assignments and Exhibits

Producer's Edge

—El Paso 2021, pet. In Posse Energy the El Paso Court of Appeals determined that the limiting language in the exhibit at issue did control, since the language in the granting instrument was “extremely broad” and the exhibit included the critical limiting language of “insofar and only insofar as.”

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Louisiana First Circuit Applies Subsequent Purchaser Doctrine to Property Transfer Involving Closely Held LLC

The Energy Law

The subsequent purchaser doctrine has been litigated extensively in Louisiana legacy cases involving claims for oilfield remediation. Energen Resources Corporation , 2021-0290 (La. 10/4/21), 2021 WL 4548529, —So. In Louisiana Wetlands, LLC v.