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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

21-0146, 2023 WL 2053175 (Tex. 17, 2023), in which it re-affirmed the axiomatic principle that a text retains the same meaning in the present day as when it was drafted. The Texas Supreme Court recently released its opinion in Van Dyke v. Navigators Grp. ,

Royalty 98
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One Man’s Waste is Another Man’s Treasure: Texas Appellate Court Holds that Produced Water Belongs to Mineral Owners

The Energy Law

In response, the Texas Legislature passed Texas Natural Resources Code § 122.002 on September 1, 2019, which grants title to produced water to whoever takes possession of it for the purpose of treating it for subsequent beneficial use, unless a conveyance instrument expressly provides otherwise. But more than minerals are released.

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Louisiana’s Sabine River Authority Not Entitled To Sovereign Immunity

The Energy Law

In a recent opinion, the Fifth Circuit Court of Appeals ruled that the “Sabine River Authority, State of Louisiana” (“SRA-L”) is not entitled to Eleventh Amendment sovereign immunity. [1] 1] SRA-L was a named defendant in a suit by plaintiffs who own land in Louisiana and Texas. Tarrant County , 798 F.2d 2d 736, 744-45 (5 th Cir.

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