Pack v. Santa Fe Minerals, a Division of Santa Fe International Corporation
Supreme Court of Oklahoma
869 P.2d 323 (Okla. 1994)
Pack (plaintiff) signed an oil and gas lease, leasing oil and gas rights on his property to Santa Fe Minerals (SFM) (defendant). The lease provided that the lease would terminate after ten years, unless the wells were producing. Specifically, the lease also stated that the lease would terminate if, after the ten-year term, production ceased for more than 60 days. The lease contained a shut-in royalty requirement, to be paid to Pack if the wells were capable of producing, but did not produce. SFM’s well on the property was capable of producing gas. SFM over-produced gas during the winter months because demand and price for the gas was highest during those months. Oklahoma Corporation Commission regulations imposed a cap on the amount of gas a single well can produce in a year. To abide by this cap, SFM did not market or produce gas during the warmer months of the year. SFM did not pay Pack royalties during these warmer months. After the initial ten-year lease term expired, Pack brought suit, claiming that the lease terminated on account of SFM’s non-production and non-payment during the summer months. The trial court found in favor of Pack and canceled the lease. The court of appeals affirmed. Pack appealed.
Rule of Law
Holding and Reasoning (Simms, 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.