Humphreys-Mexia Company v. J. L. Gammon

Summary

The Texas Supreme Court held that the reservation of oil and minerals in C. A. Kennedy's deed severed the mineral estate from the surface estate, that the later assignment of the vendor's lien notes did not convey the mineral rights, that the doctrine of merger does not apply to prevent such severance, and therefore reversed the Court of Civil Appeals and affirmed the trial court judgment.