Texas Company v. the State of Texas and Duval County Ranch Company

Summary

The Texas Supreme Court affirmed the trial court’s judgment cancelling the mineral conveyances from Duval County Ranch Company to the Texas Company, awarding the State of Texas damages for the value of oil and gas produced and interest thereon, and holding that Duval may retain the one‑sixteenth royalty proceeds as damages to its surface estate. The Court also held that the instruments were void because they conveyed a fee‑simple absolute in minerals contrary to the Relinquishment Act, and that the State was not estopped from asserting title. The Court rejected the Texas Company’s claim that it could recover the royalty proceeds from Duval, finding the claim waived. The decision was rendered on the basis that the instruments were unambiguous and invalid, and that interest on the net proceeds is a matter of law.