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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. 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.

Royalty 98
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Louisiana Legislature to Consider Amendments to Forced Pooling Regime Requiring Operators to Pay Lessors of Nonparticipating Working Interest Owners Directly

The Energy Law

On Friday, March 31, 2023, Representative Larry Bagley of Louisiana’s District 7 proposed amendments to Louisiana Revised Statutes § 30:10. As was the case in 2012, this proposed amendment would also extend this direct payment requirement to any overriding royalty interests burdening the nonparticipating owner’s lease.

Royalty 98
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Texas Supreme Court Holds that Add-Back Provision in Oil and Gas Lease Required Royalties to be Paid on Prices in Excess of the Producers’ Gross Proceeds

The Energy Law

20-0904, 2023 WL 2438927 (Tex. 2023), in which it held that lessees owed royalties in excess of their gross proceeds, specifically “adding back” costs incurred by third-party buyers that were enumerated in the sales contract and subtracted from the sales price. Sheppard , — S.W.3d

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