Summary
The Supreme Court of Ohio declined to answer a certified question concerning whether Ohio follows the at-the-well rule or the marketable-product rule for deducting postproduction costs from oil and gas royalties. The court held that oil and gas leases are contracts governed by their specific language and dismissed the cause; two justices dissented.
Holdings
- The court declined to adopt either categorical rule and dismissed the certified cause because an oil and gas lease is a contract governed by traditional contract-construction principles, and the parties' rights and remedies are controlled by the specific language of their lease.
- The court decertified or declined to answer the certified question and dismissed the cause.
Questions Presented
- Whether Ohio follows the at-the-well rule or the marketable-product rule for calculating oil and gas royalties and deducting postproduction costs.
- Whether the Supreme Court of Ohio should answer the certified question without interpreting the specific lease language and without an evidentiary record concerning extrinsic evidence.
Disposition
dismissed
Cases Cited (14)
- Harris v. Ohio Oil Co., 57 Ohio St. 118, 129, 48 N.E. 502 (1897)(followed)
- Chesapeake Exploration, L.L.C. v. Buell, 144 Ohio St. 3d 490, 2015-Ohio-4551, 45 N.E.3d 185, ¶ 53(followed)
- Skivolocki v. E. Ohio Gas Co., 38 Ohio St. 2d 244, 313 N.E.2d 374 (1974)(followed)
- Graham v. Drydock Coal Co., 76 Ohio St. 3d 311, 313-314, 667 N.E.2d 949 (1996)(followed)
- Martin Marietta Magnesia Specialties, L.L.C. v. Pub. Util. Comm., 129 Ohio St. 3d 485, 2011-Ohio-4189, 954 N.E.2d 104, ¶ 29(followed)
- United States Fid. & Guar. Co. v. St. Elizabeth Med. Ctr., 129 Ohio App. 3d 45, 56, 716 N.E.2d 1201 (2d Dist. 1998)(followed)
- State ex rel. Claugus Family Farm, L.P. v. Seventh Dist. Court of Appeals, 145 Ohio St. 3d 180, 2016-Ohio-178, 47 N.E.3d 836, ¶¶ 31-33(followed)
- Kachelmacher v. Laird, 92 Ohio St. 324, 110 N.E. 933 (1915)(followed)
- Pipeline Serviced Obligations and Revisions to Regulations Governing Self-Implementing Transportation under Part 284 of the Commission's Regulations, 57 Fed. Reg. 13,267-02 (1992)(cited)
- Piney Woods Country Life School v. Shell Oil Co., 726 F.2d 225 (5th Cir. 1984)(cited)
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Cited In (0)
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Court Document
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