Larsen v. Oil & Gas Conservation Commission
Wyoming Supreme Court
569 P.2d 87 (1977)
Apache Exploration Corporation (Apache) applied to the Wyoming Oil and Gas Conservation Commission (Commission) (defendant) to establish 80-acre drilling units for producing hydrocarbons. The Commission had the authority to establish drilling units of a specified size “[w]hen required, to protect correlative rights or, to prevent or to assist in preventing [prohibited waste].” Larsen and other royalty interest owners on some of the land subject to Apache’s application (plaintiffs) were opposed to the application because they believed that the proposed direction of the units would deprive them of their correlative rights. The Commission found that the establishment of the units would “protect correlative rights of each owner . . . in the field and [would] prevent or assist in preventing [prohibited waste].” The Commission’s order made reference to the approximate amount of oil that could be recovered from the pool as a whole. The Commission’s order did not, however, reference the plaintiffs’ correlative rights, nor did it state the amount of oil that could be recovered under the various units established in the order. The order also did not determine how much oil could be recovered without waste. The plaintiffs appealed the order of the Commission. The district court affirmed the order. The plaintiffs appealed.
Rule of Law
Holding and Reasoning (Rose, J.)
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