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. That rationale led to the Court’s holding that the mere use of one-eighth in a double fraction is some evidence that the parties were operating under the estate misconception theory.
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