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Fontenot v. Humble Oil & Refining Co.

Court of Appeal of Louisiana
210 So. 2d 340 (La. Ct. App. 1968)


Facts

Agnes Fontenot (plaintiff) and the Landreneaus issued an oil and gas lease to Humble Oil & Refining Company (Humble) (defendant). The lease covered three tracts of land and described each tract, including total acreage. Fontenot owned a mineral interest in Tracts 2 and 3, but no interest in Tract 1. The Landreneaus owned the other interests subject to the lease. The lease did not specify which parties owned which tracts of land. The lease stated that it would terminate after one year unless Humble began drilling operations. Humble drilled wells on Tract 1 within one year, extending the term of the lease. Fontenot sent a letter to Humble, stating that Fontenot owned no interest in Tract 1 and did not intend to pool royalties with the Landreneaus. Based on the letter, Humble paid the Landreneaus royalties based on production from the wells. Fontenot brought suit against Humble to cancel the lease, claiming that the lease was not a joint lease and that because there was no production on the tracts owned by Fontenot, the lease was terminated as to her interests. The trial court found in favor of Humble and dismissed the suit. Fontenot appealed.

Rule of Law

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Issue

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Holding and Reasoning (Savoy, J.)

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  • A “yes” or “no” answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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