Evelyn Tittizer v. Union Gas…

Summary

The Texas Supreme Court held that the pooling provisions of the oil and gas leases required the effective date of a pooled unit to be the date the designation was recorded, not the date of first production, so Tittizer is only entitled to royalties after that date. The Court also found that Union Gas was not estopped from asserting the recordation date and that the appellate court erred in finding the attorneys’ fees award was not preserved, remanding for consideration of its reasonableness.