Summary
The Wyoming Supreme Court reviewed a dispute over whether a 4% overriding royalty reserved in assignments of two state oil and gas leases extended to a later lease covering the same land. The court held that the later Ribbe Lease was not a renewal lease, substitute lease, or new lease issued in lieu of the earlier leases under the assignment language, reversed the district court’s judgment, and remanded the case.
Holdings
- The Ribbe Lease was not a renewal lease, substitute lease, or new lease issued in lieu of the 505 and 529 Leases. It was an entirely new lease, issued on different terms to a different lessee through a public drawing, so Davis's overriding royalty ended when the original leases terminated and did not attach to the Ribbe Lease.
Questions Presented
- Whether the Ribbe Lease was a renewal lease, substitute lease, or new lease issued in lieu of the 505 and 529 Leases under the State Land Board assignment language.
Disposition
reversed_and_remanded
Cases Cited (15)
- Sawyer v. Guthrie, 215 F. Supp. 2d 1254, 1258 n.2, 1264 (D. Wyo. 2002)(cited)
- Ultra Resources v. Hartman, 2010 WY 36, 226 P.3d 889 (Wyo. 2010)(distinguished)
- Fayard v. Design Committee of the Homestead Subdivision, 2010 WY 51, 230 P.3d 299, 302 (Wyo. 2010)(cited)
- Caballo Coal Co. v. Fidelity Exploration & Production Co., 2004 WY 6, 84 P.3d 311, 313 (Wyo. 2004)(cited)
- Moats v. Professional Assistance, LLC, 2014 WY 6, 319 P.3d 892, 896 (Wyo. 2014)(cited)
- Union Pacific Railroad Co. v. Caballo Coal Co., 2011 WY 24, 246 P.3d 867, 871 (Wyo. 2011)(cited)
- M & M Auto Outlet v. Hill Investment Corp., 2010 WY 56, 230 P.3d 1099, 1104 (Wyo. 2010)(cited)
- Leithead v. American Colloid Co., 721 P.2d 1059, 1063-64 (Wyo. 1986)(cited)
- Alexander v. Phillips Oil Co., 707 P.2d 1385 (Wyo. 1985)(cited)
- Moncrief v. Williston Basin Interstate Pipeline Co., 880 F. Supp. 1495, 1514 (D. Wyo. 1995)(cited)
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Cited In (0)
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Court Document
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