Lightning Oil Co. v. Anadarko E&P Onshore, LLC
Texas Supreme Court
520 S.W.3d 39 (2017)
Anadarko E&P Onshore, LLC (Anadarko) (defendant) leased minerals located below a state-controlled wildlife-conservation area in Texas. The lease restricted Anadarko from drilling activities on the surface of the conservation area and required Anadarko to drill from offsite locations if prudent and feasible to do so. Anadarko entered an agreement with Briscoe Ranch, Inc. (Briscoe), the owner of surface ranchland adjacent to the conservation area, allowing Anadarko to drill down vertically from the ranch surface and then use horizontal drilling to produce minerals from Anadarko’s leased area. Lightning Oil Company (Lightning) (plaintiff) leased the minerals under the ranch and objected to Anadarko’s agreement with Briscoe because Anadarko’s vertical wellbores (i.e., the holes for the well) would pass through portions of Lightning’s leased mineral-bearing formations and would remove some mineral-bearing material during the drilling process. Lightning sued to enjoin Anadarko from drilling on the ranch, asserting claims including trespass. Lightning claimed that mineral lessees have the right to preclude surface owners or adjacent lessees from drilling through the mineral lessees’ mineral-bearing formations and, therefore, that Lightning’s consent was necessary before Anadarko could drill through the areas covered by Lightning’s mineral lease. The trial court dismissed Lightning’s action, and the appellate court affirmed, holding that Anadarko needed only Briscoe’s permission to drill. The appellate court explained that a surface owner’s rights include the right of ownership of geological structures and all nonmineral molecules of land beneath the surface. The appellate court thus concluded that because Lightning did not own or exclusively control the earth surrounding the minerals under the ranch, Lightning had no right to exclude Anadarko. Lightning appealed to the Texas Supreme Court.
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 711,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.Unlock this case briefRead 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.Learn about our approachRead more about Quimbee
Here's why 711,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 44,600 briefs, keyed to 983 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.