Southland Royalty Company v. Humble Oil & Refining Company

Summary

The Texas Supreme Court affirmed the trial court's declaratory judgment in favor of Southland Royalty Company, holding that the 1925 mineral deed was effectively modified by the 1932 unitized lease so that production from any tract extended the deed's term beyond twenty years. The Court relied on established Texas unitization precedent to conclude that the parties intended such an extension.