Texaco, Inc. v. Short
United States Supreme Court
454 U.S. 516 (1982)
Indiana enacted a statute providing that a mineral interest would be extinguished and reverted to the surface owner if the mineral estate went unused for 20 years. Production, receipt of rent or royalties, and payment of taxes each constituted use of the interest. Alternatively, a mineral-interest holder could avoid the effect of the statute by filing a statement of claim with a local registrar of deeds. The statute did not require notice to the mineral-interest holder prior to the expiration of the 20-year term. The statute did contain a two-year grace period after its passage to allow owners who had not used their mineral interests in over 20 years to file a statement of claim. Texaco, Inc. (Texaco) (plaintiff) was a mineral-interest holder on a tract of land and had not used its mineral interest for more than 20 years when the statute was passed. Texaco did not file a statement of claim within the two-year grace period. Texaco brought suit, alleging that the statute was unconstitutional because the lack of a notice provision violated due process, and because the statute effected a taking of Texaco’s property without just compensation. The trial court found in favor of Texaco. The Indiana Supreme Court reversed the trial court and upheld the statute. The United States Supreme Court granted certiorari.
Rule of Law
Holding and Reasoning (Stevens, J.)
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