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. Element Petroleum Props., Texas courts refer to this phenomenon as the “estate-misconception” theory. Dawkins , 483 S.W.3d 11-21-00103-CV (Tex. Eastland June 1, 2021).
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