Quimbee logo
DMCA.com Protection Status
From our private database of 18,400+ case briefs...

Butler v. Charles Powers Estate

Supreme Court of Pennsylvania
65 A.3d 885 (2013)


In 1881, Charles Powers conveyed a tract of land to the predecessors in interest of John and Mary Butler (plaintiffs) and reserved “one-half [of] the minerals and Petroleum Oils” in the land. In 2009, the Butlers sued the Charles Powers Estate (Estate) (defendants) and its heirs and assigns (defendants) to quiet title in the land, including all the minerals and petroleum oils beneath the property. William and Craig Pritchard, the rightful heirs to the Estate, filed a motion for a declaratory judgment, seeking a ruling that the deed reservation included one-half of all natural gas located beneath the surface of the land. The Estate claimed that the reservation, by using the term “minerals,” included natural gas within a shale formation below the surface of the land. The Butlers claimed that the deed did not reserve any natural gas, because the deed did not explicitly state that natural gas was being reserved. The Susquehanna County Court of Common Pleas found in favor of the Butlers. The superior court reversed. The Butlers appealed.

Rule of Law


Holding and Reasoning (Baer, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 497,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.

  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.

Here's why 497,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 18,400 briefs, keyed to 985 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Questions & Answers

Have a question about this case?

Sign up for a free 7-day trial and ask it

Sign up for a FREE 7-day trial