Carson v. Railroad Commission
Supreme Court of Texas
669 S.W.2d 315 (Tex. 1984)
John Lee Carson (plaintiff) owned a royalty interest in several adjacent tracts of land subject to oil and gas leases. The tracts were subject to a proration unit established by the Texas Railroad Commission (Commission) (defendant). The lease on Carson’s tract did not grant authority to pool, but some of the leases on the other tracts in the proration unit did permit pooling. BTA Oil Producers (BTA), a lessee, drilled a well on Carson’s tract and began producing in paying quantities two months thereafter. Two months later, BTA submitted a proposal to all of the royalty owners in the proration unit, proposing to pool the tracts and split the oil production on an acreage basis. Because the well was on Carson’s tract, Carson’s interest in the well’s production stood to be reduced by approximately two-thirds under BTA’s offer. Carson attempted to negotiate with BTA, but BTA refused. Carson refused to accept BTA’s offer, and was the only royalty owner in the proration unit to do so. BTA filed an application with the Commission to compel pooling of the tracts. The Commission granted BTA’s application and forced pooling of the tracts. Carson brought suit, seeking to have the Commission’s order vacated. The trial court upheld the Commission’s order. The court of appeals affirmed. Carson appealed.
Rule of Law
Holding and Reasoning (Wallace, J.)
What to do next…
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 97,000 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.
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 173,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 14,000 briefs, keyed to 188 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.