Central Natural Resources, Inc. v. Davis Operating Co.
Kansas Supreme Court
201 P.3d 680 (Kan. 2009)
A landowner conveyed to Central Natural Resources, Inc.’s (Central) (plaintiff) predecessor in interest “all coal without reference to quality or quantity . . . together with the right to mine and remove same.” The coalification process produced coalbed methane gas (CBM) and other gases. Some of the CBM remained in the coal after it was processed. At the time of the conveyance, the general understanding of CBM was that it was a dangerous gas with no value. Subsequently, Davis Operating Co. and other oil and gas companies (defendants) obtained oil and gas leases from the landowner. The defendants drilled on the land and produced CBM. Central filed a quiet title action to assert its ownership of the produced CBM. Central argued that CBM was produced by the coalification process. According to Central, this meant that given CBM’s origins, it should be considered part of the coal estate. In addition, Central urged the court to adopt a rule that if a coal deed was the first mineral conveyance on a tract of land, the owner of the coal rights also obtained ownership of all other substances within the coal formation. The trial court granted the defendants’ motion for summary judgment. Central appealed.
Rule of Law
Holding and Reasoning (Johnson, 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 175,000 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.