M. E. Trapp v. Shell Oil Company, Incorporated

Summary

The Texas Supreme Court reversed the lower courts and upheld the Railroad Commission's permit to drill a second well, holding that the proper standard of review is the substantial‑evidence rule announced in Gulf Land Co. v. Atlantic Refining Co.; the trial court must apply that rule rather than substitute its own fact findings, and the applicant need not present perfect paper title, only a good‑faith claim of ownership. Justice Alexander dissented, arguing that the majority improperly limits judicial fact‑finding and infringes constitutional rights.