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
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.” Texas courts refer to this phenomenon as the “estate-misconception” theory.
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