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 support of that notion, the Court cited the 1957 Texas Supreme Court case Garrett v. Element Petroleum Props., Dils Co. , 2d 904 (Tex. 11-21-00103-CV (Tex.
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