Texas Supreme Court Denies Review on Rolling/Snapshot Retained Acreage Case

Apache Deepwater, LLC v. Double Eagle Dev., LLC, 557 S.W.3d 650 (Tex. App.—El Paso 2017, pet. denied Dec. 14, 2018)

Retained acreage provisions continue to be a popular subject in Texas oil and gas law. The Texas Supreme Court recently denied a petition for review in the closely-watched case, Apache v. Double Eagle. In that case, the parties disagreed as to whether a retained acreage clause provided for a single partial termination at the end of the primary term (i.e., a “snapshot-in-time” termination), or a continuous partial release throughout the secondary term (i.e., “rolling termination”). This case bolsters the old adage: “say what you mean and mean what you say.” Texas courts will not fill in the blank otherwise.

The facts of the Apache case are fairly straightforward. The dispute involved a 1975 lease covering 640 acres in Reagan county, which was divided up into four proration units, each with its own producing well. However, several years after the primary term had expired, three of the four wells ceased production. Apache later acquired that lease by assignment.

In 2012, Double Eagle acquired a lease covering the three sections where production had ceased. Apache balked, claiming that its one remaining well was sufficient to hold the entire 640-acre lease. The dispute turned on the retained-acreage clause, which read as follows:

Notwithstanding anything to the contrary…Lessee covenants to release this lease after the primary term except as to each producing well on said lease, operations for which were commenced prior to or at the end of the primary term and the proration units as may be allocated to said wells…

Double Eagle argued that language provided for a “rolling” termination, and therefore each unit terminated as its well ceased producing. However, Apache argued that this clause provided for a single “snapshot” termination, essentially applying one time at the end of the primary term. Under Apache’s reading, because all four wells were producing at the end of the primary term, there would be no partial termination later down the road as long as one well was producing in paying quantities.

The El Paso Court of Appeals held in favor of Apache, explaining (1) this is not the sort of “clear, precise, and unequivocal language” Texas courts require to limit a habendum clause, (2) this habendum clause broadly described that production would extend the entire “leased premises.”

The court was not persuaded by Double Eagle’s arguments that (1) the phrase “after the primary term” in the habendum clause means the same thing to the industry as “during the secondary term,” or (2) that the phrase “notwithstanding” automatically shows that the parties intended the retained acreage provision to be contrary to the habendum clause.

The takeaway? Parties desiring a rolling termination should take care to draft “clear, precise, and unequivocal” language.


Highway to Oil: Strip-And-Gore Leads to 30-Acres of Minerals Underlying a Highway

Green v. Chesapeake Expl., L.L.C., No. 02-17-00405-CV, 2018 Tex.; App. LEXIS 10307 (Tex. App.—Fort Worth Dec. 13, 2018, no pet.)

In urban oil and gas plays such as the Barnett Shale, horizontal drilling has “paved the way” for oil and gas operators to drill through and produce minerals underlying highways, streets, and roadways. Even in rural areas across Texas, numerous horizontal wells have been drilled underneath roads and highways. As a result, several reported cases in recent years have involved title to minerals underlying roadways. Landmen of the vertical era may have paid little attention to mineral title underlying roadway tracts. After all, one option may have been simply to drill the vertical well next to the road or to omit the roadway tract from the unit. However, horizontal drilling significantly altered this analysis, as geological implications and long horizontal laterals may dictate that the horizontal wellbore pass under the roadway, significantly increasing the odds that a roadway tract will be a “drillsite tract.” The result is that mineral title and pooling issues are more likely of critical concern.

An important doctrine relating to roadways is the strip-and-gore doctrine and the centerline presumption. Some may (erroneously) think of the strip-and- gore doctrine as applying only to extremely small strips of land, such as when updated surveys slightly deviate from prior boundary lines. However, as was recently illustrated in Green v. Chesapeake, 2018 Tex. App. LEXIS 10307 (Tex.Civ.App.—Fort Worth 2018, no pet.), the strip-and-gore doctrine can actually apply to relatively large tracts of land.

In Green v. Chesapeake, the Fort Worth Court of Appeals analyzed the “strip-and-gore” doctrine in determining ownership of minerals underlying a 30-acre parcel underlying a Highway. The case involved two deeds: (1) a 1970 deed, conveying the eastern 30-acres of an 85-acre tract to the State of Texas for the highway, reserving all mineral rights, and (2) a 1972 deed conveying the remaining 55 acres to successors, with no mineral reservation, and with no mention of the 30-acre highway tract. Years later, the question arose as to whether the 1972 deed also conveyed the severed 30-acre mineral interest by way of the strip and gore doctrine.

The Fort Worth Court of Appeals held that the strip-and-gore doctrine does not require any showing of ambiguity, and held that there is no exact size ration that must be found for the doctrine to apply.

Instead, the court held that the stripand-gore doctrine requires just three elements: (1) the adjoining land is of a certain character—relatively narrow, small in size and value in comparison to the expressly conveyed land, and no longer of importance or value to the grantor of the larger tract, (2) the adjoining land was not included in the property description in the deed at issue, and (3) no other language in the deed indicates that the grantor intended to reserve an interest in the adjoining land.

The court held that size is not an independent element, but rather an indicator of the value of the tract to the grantor, such as whether it was developable or usable.

The Green court focused its analysis on the value of the minerals underlying the highway, and noted that the 1970 deed waived all rights of ingress and egress. The court concluded that the minerals would be “wholly worthless if the owner…could not enter upon the land in order to explore for and extract them.”

The Green court acknowledged that minerals underlying the highway may have significant value with today’s horizontal drilling technology. However, the court noted that the strip-and-gore doctrine is an aid to determine the parties’ intent, and the 1972 deed was executed during a time when vertical wells predominated Texas’ oil and gas production. The Green court stated that it was not willing to “conclude that [the grantor] intended to retain ownership indefinitely in a property interest that to it was inaccessible and then undevelopable, with the future hope that one day it would benefit from that interest, either via pooling or the advent of technology.”


Texas Court Addresses the Use of Contract Operators

OBO, Inc. v. Apache Corp., 2018 Tex. App. LEXIS 8392,
(Tex.Civ.App.—Houston [14th Dist.] 2018, no pet.)

Parties to a joint operating agreement sometimes elect to have a non-owner serve as the operator. For example, interest owners may determine that they are unwilling or unable to perform the operator duties under the operating agreement, and will instead elect hire an unaffiliated contract operator. However, placing a non-owner in the position of operator is problematic for a number of reasons. For example, most model form operating agreements either directly or indirectly indicate that ownership is a condition precedent to serving as operator. Moreover, numerous obligations, protections, and other provisions of model form operating agreements may become confusing, unworkable, or even meaningless when applied to a non-owning operator.

Some of those issues are illustrated by the recent case OBO, Inc. v. Apache, involving the American Petroleum Institute’s Model Form Unit Agreement and Model Form Unit Operating Agreement. In that case, the Houston 14th District Court of Appeals was faced with determining whether an elected Unit Operator is permitted to delegate operatorship duties to a contract operator, and whether that contract operator can be liable to nonoperators for breach of any duties imposed on the operator under that Unit Operating Agreement.

PBJV (the owner of 81.4% interest) was designated as unit operator, but then PBJV entered into a contract with Apache to perform a number of those duties, including an obligation to submit JIBs on behalf of PBJV. OBO (a minority working interest owner), declined to pay a number of JIBs and Apache filed suit. OBO filed a counter-claim, alleging that Apache lacked standing because the API Unit Operating Agreement indicates that the “Unit Operator” must be a working interest owner.

OBO also filed a counterclaim against Apache for breach of an alleged duty under the API Unit Operating Agreement to act as a reasonably prudent operator, and claimed that the exculpatory clause did not serve to limit Apache’s liability. The trial court granted summary judgment against OBO, and this appeal followed.

The Houston 14th District Court of Appeals indicated it was undisputed that only a working interest owner can be designated as the Unit Operator under the API Unit Operating Agreement. Instead, the Court framed the dispute as whether Apache was actually acting as the Unit Operator or was merely delegated operator duties. The Court concluded that Apache was merely delegated duties, based on its observations that PBJV never actually named or designated Apache as the “Unit Operator,” but instead entered into a “Contract Services Agreement” and power of attorney with Apache under which PBJV contractually delegated certain operator duties to Apache. The Court also noted that the contract expressly indicated that Apache was “subject to the reasonable direction of PBJV.”

OBO claimed that the API Model Form prohibited delegation of operator duties. OBO argued that allowing delegation of operator duties would render meaningless the definition of “Unit Operator,” defining that term as the party “acting as operator and not as a Working Interest Owner.” However, the court disagreed, explaining “it is not reasonable to interpret this sparse language as creating a prohibition against delegation.” Instead, the court explained that a more reasonable explanation is that the definition is merely intended to differentiate between the Unit Operator’s actions as operator and actions as owner.

OBO also argued that allowing delegation of operator duties would render meaningless the operator removal language in Section 6.2 of the API Model Form, which allows nonoperators to vote among themselves to remove the operator. OBO argued that, if PBJV were allowed to delegate operator duties to Apache, then PBJV could nullify OBO’s protection under Section 6.2 by voting its 81.4% interest in favor of keeping Apache. However, the Court disagreed with OBO, explaining that because PBJV was the Unit Operator, not Apache, this Section 6.2 was unaffected by PBJV’s delegation of operator duties to Apache.

Finally, the Court also disagreed with OBO regarding its breach of duty claim against Apache. The court noted that, while the only duty OBO alleged was under the Unit Operating Agreement, Apache could not owe any duties under that agreement because Apache was not a party to that agreement. As the Court explained, “it is axiomatic that a contract between other parties cannot create an obligation or duty on a noncontracting party.” As a result, the Court did not expressly address OBO’s related claim that the exculpatory clause did not limit Apache’s liability.

Takeaways and Insights

As the OBO case illustrates, numerous issues can arise when parties elect to engage a non-owning operator. As a result, JOA parties seeking to appoint a non-owner as operator often expressly address the subject through custom provisions in the operating agreement or by separate written agreements. For example, some operating agreements include within their custom provisions a paragraph expressly granting the designated operator the right to delegate duties to a third party operator as an independent contractor, and addressing the non-operators’ rights and obligations with respect that contract operator.

AAPL’s Model Form-610 Operating Agreement itself was updated in 2015 to include a provision addressing the use of non-owner operators. The 2015 version of that form includes a new provision in article V.A. expressly allowing non-owning operators but expressly requires, as a condition precedent, the non-owner operator and the non-operators to first enter into a separate agreement governing their relationship. This “separate agreement” is a firm condition precedent under the 2015 form, as the provision goes on to explain that “the failure of a non-owning operator and Non-Operators to enter into such a separate agreement…shall disqualify said non-owning operator from serving as Operator, and a party owning an interest in the Contract Area must instead be designated as Operator.”

The use of a non-owning operator involves numerous complicated and delicate issues, such as the relationship between the owners and the non-owning operator, the non-owning operator’s tenure, compensation, authority, liability, and duties. Those issues should generally be addressed in an agreement between the JOA parties and the nonowning operator, such as the “separate agreement” contemplated within the new 2015 form. In fact, the new provision contained within the 2015 form is largely silent as to the parties’ relationship, impliedly assuming the parties will address these issues within their separate agreement.


Four Recent Drainage and Offset Cases: A Texas Litigation Trend?

Three recent Texas cases have focused on the interpretation of express offset provisions in oil and gas leases.  Over the last year, the Texas oil and gas industry has experienced what some commentators have called “Shale Boom 2.0,” with increased drilling activity in South Texas and the Permian Basin, leading to some marketing bottlenecks and spikes in the number of drilled but uncompleted wells.

Whatever the cause, at least three reported appellate cases in the last 18 months have focused on the construction of express offset clauses in oil and gas leases.  Oil and gas landmen and lawyers alike should take note of these decisions, as they each underscore that Texas courts do not interpret oil and gas leases merely by reference to the industry’s general rules, but instead on a careful analysis of the actual language used by the parties in the lease.  And as one recent case illustrates, the “surrounding circumstances” of the shale boom might lead to results some would not expect.

Murphy v. Adams: “offset well” did not mean well that would actually protect against drainage

Earlier this year, we summarized Murphy Expl. & Prod. Co.-USA v. Adams, 560 S.W.3d 105 (Tex. 2018).  In that case, the Texas Supreme Court held that, in light of the “surrounding circumstances” of the Eagle Ford shale, the phrase “offset well” in that particular lease did not require the drilling of a well that would actually protect against drainage.  Instead, the Court held that “offset well” merely referred to a well drilled anywhere on the leased premises, so long as it was drilled down to the depth required under the lease.

That case involved an “offset” clause in a 2009 oil and gas lease.  The majority reached its conclusion based on interpreting that term in light of the “surrounding circumstances” evidence of the discovery of the Eagle Ford and drainage patterns of horizontal shale wells. 

Four justices dissented in an opinion that, among other things, criticized the majority opinion for disregarding the commonly understood meaning of the phrase “offset well,” which they described as being a well designed to protect the leasehold from drainage.

The clause at issue in the Murphy v. Adams case read as follows:

…in the event a well is completed as a producer of oil and/or gas on land adjacent and contiguous to the leased premises, and within 467 feet of the premises covered by this lease, that Lessee herein is hereby obligated to…commence drilling operations on the leased acreage and thereafter continue the drilling of such off-set well or wells with due diligence to a depth adequate to test the same formation from which the well or wells are producing from on the adjacent acreage.

When a well on a neighboring tract triggered this clause, Murphy drilled a well 1,800 feet from the lease line and 2,100 feet away from the triggering well.  Murphy argued that this well satisfied the offset well requirement because it was drilled on the leased premises and to the same depth as the neighboring well.  The lessor argued the well did not qualify as an offset well because it was not designed to protect against drainage.

The majority noted that this offset clause did not expressly require that the offset well be drilled in any specific location.  The majority’s holding was largely founded on “surrounding circumstances” evidence – the fact that the leases were executed in 2009 and the leases were drafted with horizontal shale drilling in mind.  The Court noted that “commentators have recognized” that “little or no drainage will occur between the two tracts” in a shale play, assuming one is drilled and the other is not.  Based on this understanding, the Court concluded that the parties must have not intended for an offset well to be drilled in a location to protect against drainage, referring to any other conclusion as “illogical.”  The Court limited its holding to “the circumstances at hand, which involve unconventional production in tight shale formations.”

Four justices dissented in an opinion that complained that the majority was “explaining on behalf of Murphy” why the parties who negotiated leases (which did not include Murphy) could not have intended for the phrase “offset well” to retain its traditional meaning.  The dissent concluded that the phrase “offset well” required Murphy to drill its offset well at a location where a reasonably prudent operator would drill a well to protect the leasehold from actual or potential drainage, whether or not any was occurring.  The dissent complained that the Court’s holding effectively stripped the lessors of any leasehold protections that the offset clause could have been designed to protect and that the word “offset,” as used in the lease, would have no meaning.

It should be noted that all parties agreed that this offset clause could be triggered regardless of whether there was actual drainage, thereby distinguishing this clause from the implied covenant to protect from drainage.

It is yet to be seen whether, and to what extent the Court’s willingness to interpret leases through the lens of unconventional drilling will have on other lease provisions, and the role, if any, of expert engineering testimony in shaping what is seen through that lens.

Martin v. Newfield: Offset obligation not triggered due to separation by narrow strip of land

In another recent Texas case, Martin v. Newfield Exploration Co., No. 13-17-00104-CV, 2018 Tex. App. LEXIS 2435 (App.—Corpus Christi Apr. 5, 2018), the Corpus Christi Court of Appeals held that another express offset clause was not triggered because the provision indicated that a triggering well must be located on an “adjoining” tract.  In that case, a narrow strip of land separated the unit containing the nearby well and the unit that contained the plaintiff’s lease.  The defendant oil and gas company argued that, because the tracts of land were separated by this narrow strip of land, they were not truly “adjoining” and therefore the offset clause was not triggered.

In Martin, the clause at issue provided as follows:

…in the event a well is drilled on or in a unit containing part of this acreage or is drilled on acreage adjoining this Lease…the Lessee shall spud an offset well…

The Corpus Christi Court of Appeals began by indicating that whether this obligation was triggered was a matter of construing “the intention of the parties as it is expressed in the lease.”

The court, in turn, concluded that question was resolved by the definition of the word “adjoining.”  The court reviewed a few cases that previously held that “adjoining” means “lying next to, adjoining to, uniting, being in contact” as well as “touching or sharing a common boundary.” Based on these definitions, the Martin Court held that the two units were not “acreage adjoining” because they were separated by another strip of land.  As a result, any “duty to prevent drainage and spud an offset well…was not triggered as a matter of law.”

Mzyk v. Murphy: Offset obligation not triggered where reasonable prudent operator would not have drilled an offset well

In Mzyk v. Murphy Expl. & Prod. Co.-USA, No. 04-15-00677-CV, 2017 Tex. App. LEXIS 5930 (App.—San Antonio June 28, 2017), the San Antonio Court of Appeals analyzed whether an offset provision required the lessee to drill an offset well even if a reasonable prudent operator would not drill an offset well in similar circumstances. The landowner argued that Murphy had the obligation even if a prudent operator would not drill the well, and sought $11 million in compensatory royalties and attorney’s fees.

The offset clause at issue read (in part) as follows:

If…any new well or wells is drilled…on adjacent lands…and within four hundred sixty seven feet (467’) from said lands, Lessee agrees to drill such offset well or wells on said lands (or attempt to complete for production any existing offset well or wells drilled by Lessee on said lands) as a reasonably prudent operator would drill under the same or similar circumstances…

The dispute focused on the effect of the emphasized language quoted above.  Murphy argued that this language meant Murphy had no requirement to drill an offset well if a reasonably prudent operator under similar circumstances would not drill an offset well.  The landowner, on the other hand, argued that the first part of the paragraph indicated when Murphy was required to drill an offset well, and the emphasized language merely dictated how Murphy was to drill that well.

The court of appeals interpreted the phrase as expressly adopting the reasonably prudent operator standard. The court further explained that, in the context of an offset obligation, the reasonably prudent operator standard also determines whether to drill an offset well, not merely how to drill an offset well.

The court of appeals rejected the lessor’s arguments that the offset clause was drafted as a “modern lease that presumes drainage is occurring” if another well is drilled within 467 feet.  The court noted that the modern clauses the landowner quoted were “substantially different,” because the clause in this case “contains no language suggesting the parties agreed to a presumption of actual or substantial drainage.”

The landowner also argued that Murphy should have paid compensatory royalties under another provision which specified that, if Murphy did not “build an offset well,” then it had to either pay compensatory royalties or deliver a release of the lease.  However, the court disagreed, reasoning that the reference to “offset well” in that provision refers back to the offset well clause, which had incorporated the reasonably prudent operator standard.

Bell v. Chesepeake

On March 13, 2019, the San Antonio Court of Appeals issued its opinion in Bell v. Chesapeake Energy, Cause No. 04-18-00129-CV (Tex.Civ.App.—San Antonio, 2019 no pet), involving a dispute as to whether a particular offset clause in that case adopted the reasonable prudent operator standard, and the calculation of compensatory royalties.  This case will be discussed in Part Two of this article.

 Takeaways and Insights

The oil and gas industry can sometimes be heavy on jargon and the use of broad guiding principles.  However, as these recent cases illustrate, Texas courts analyzing express offset provisions do not merely adopt the industry’s general rules, but instead focus their analysis on the interpretation of the specific language utilized by the parties in the oil and gas lease.

These cases illustrate that companies examining their offset obligations or negotiating new leases should pay close attention to the wording of any offset provisions, including potential references to reasonable prudent operator standards, how the provision describes when the obligation is triggered, and the description of resulting obligation.  Parties should also keep in mind potential arguments regarding how “surrounding circumstances” shed different light on the language. However, the sharp dissent in the Murphy v. Adams case is likely to motivate counter-arguments disputing the efficacy of such evidence in lease construction cases.


Introducing the first edition of Producer’s Edge

McGinnis Lochridge’s Oil & Gas Newsletter: Producer’s Edge keeps clients informed about Texas oil and gas case law, regulatory updates, and insightful articles relevant to the oil and gas community. In this first edition, we highlight several recent Texas oil and gas cases. We also highlight Partner Donald D. Jackson, and his recent article, Can A Driller Trespass While Fracking On Its Own Lease? You’ll also find our article listing a brief summary of several oil and gas cases pending in front of the Texas Supreme Court.

Download the first issue of Producer’s Edge here.


Appellate Court Holds that Landowner’s “Course of Dealing” Leads to Waiver

In June 2018, the Dallas Court of Appeals issued its memorandum opinion in Tollet v. Surface, holding that an ambiguous royalty provision in a groundwater lease, when read in light of the parties’ course of dealings, allowed the lessee to make royalty payments once per month with a 90-day grace period. The court also reviewed the landowner’s “course of conduct,” including a “continual failure” for four years to demand strict performance of royalty timing and metering provisions, and held that this resulted in a waiver of the lessee’s breach of those provisions.

Water companies and oil and gas operators alike may be interested in this case, as it underscores the importance of carefully drafting royalty and metering provisions, and illustrates the use of a “waiver” defense in a breach of lease case.

Read More »


Tex. Supreme Court Splits Over Meaning of “Offset Well” in Shale Plays

The Texas Supreme Court issued a narrow 5-4 opinion in Murphy Exploration & Production Co. — USA v. Adams on June 1, 2018, interpreting a common “offset” clause contained in a 2009 oil and gas lease.  The majority held that the phrase “offset well” in that clause does not necessarily refer to a well that would protect the leasehold against drainage, but instead referred to a well drilled anywhere on the leased premises that was drilled to a depth required by the lease. The Court reached this conclusion based on interpreting that phrase in light of “surrounding circumstances” evidence of the discovery of the Eagle Ford and drainage patterns of horizontal shale wells.  Four justices dissented in an opinion that, among other things, criticized the majority opinion for disregarding the commonly understood meaning of the phrase “offset well,” which is a well designed to protect the leasehold from drainage.

Read More »


Slideshow: Production in Paying Quantities

This afternoon, I will be presenting at the Dallas Bar Association’s 31st Annual Review of Oil & Gas Law on the topic “Production in Paying Quantities.”

Here is a copy of my slides:

[slideshare id=78735738&doc=201708-10ppqpresentation-170810144445]

The Texas Supreme Court Decides Whether “Subject To” Clause Alters Who Must Bear NPRI Burden

The Texas Supreme Court Decides Whether “Subject To” Clause Alters Who Must Bear NPRI Burden

In a decision that focuses on the parties’ intent as expressed within the four corners of the document, the Texas Supreme Court in Wenske v. Ealy [1]13-15-00012-CV, ___ S.W.3d ___ (Tex. 2017) decided whether the language of a deed puts the entire burden of an outstanding non-participating royalty interest (“NPRI”) on the grantees or whether the NPRI proportionately burdens both the grantor’s reserved interest and the interest conveyed to the grantees.  The grantors argued that their reserved interest is not burdened by the NPRI, while the grantees argued that the NPRI proportionately burdens both their interest and the grantors’ interest.  The Court ruled that, based on the language in the deed, the NPRI proportionately burdens both the conveyed and reserved interest.

Read More »

Footnotes   [ + ]

Railroad Deed Controversy: 100+ Year Old Instrument Ruled an Easement, Not a Fee Simple Conveyance

Railroad Deed Controversy: 100+ Year Old Instrument Ruled an Easement, Not a Fee Simple Conveyance


BNSF Railway Co. v. Chevron Midcontinent, LP

This dispute arises from a deed executed in 1903 from W.H.C. Goode to BNSF’s predecessor covering land in Upton County, Texas.  When Chevron began producing from underneath BNSF’s railway tracks, BNSF sued for trespass of title, arguing that the 1903 deed conveyed fee simple title.  Chevron argues that BNSF acquired only an easement.  Thus, the issue before the Court was whether the parties to the 1903 deed intended to convey fee simple title or only an easement.  Although the deed contained the term “fee simple” in the habendum clause, the court ultimately decided the deed conveyed an easement because it contained terms throughout the deed that suggested the parties intended to convey only an easement.  Read More »

© Copyright 2012-2018, McGinnis Lochridge LLP. All Rights Reserved. DISCLAIMER: The information in this article is for general information purposes only. This article should not be substituted for legal advice and should not be taken as legal advice for any individual case or situation. This information is not intended to create, and receipt or reading this article does not constitute, an attorney-client relationship. You are encouraged to contact an attorney for legal advice concerning the information provided in this article.
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Note: When choosing facebook or google, alerts will be sent to the email listed in that account.
We keep clients and subscribers updated on case law alerts and insightful articles. Join more than 2,000+ in-house attorneys and landmen who receive our occasional alerts and summaries. All for free!