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Humberston v. Chevron U.S.A., Inc.

Superior Court of Pennsylvania
75 A.3d 504 (Pa. Super. Ct. 2013)


Facts

Paul and Carol Humberston (plaintiffs) owned a tract of land and leased the mineral rights to the predecessor in interest of Chevron U.S.A., Inc. (Chevron) (defendant) in 2006. The lease stated that Chevron’s predecessor was entitled to subsurface minerals, as well as any “exclusive rights as may be necessary or convenient for [Chevron’s predecessor] . . . to explore for, develop, produce, measure, and market production from the Leasehold, and from adjoining lands, using methods and techniques which are not restricted to current technology.” Chevron constructed a freshwater-storage impoundment on the Humberstons’ land. The impoundment was necessary for Chevron to be able to conduct hydraulic fracturing (hydrofracking), a process that Chevron deemed necessary to extract minerals from the land and other lands within the Humberstons’ pooled unit. In 2011, the Humberstons brought suit to quiet title and for trespass, alleging that Chevron did not have the right under the lease or otherwise to construct the impoundment. The trial court dismissed the Humberstons’ complaint. The Humberstons appealed.

Rule of Law

Issue

Holding and Reasoning (Bender, J.)

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