By Anna Knull:
In Hamilton v. Morris Resources, Ltd., the San Antonio Court of Appeals affirmed a decision in favor of holders of oil and gas deeds executed in the 1920s and 1930s over the claims of lessor, holding that, based on the four corners of the conveyances in question, the original deed holders did not intend to convey mineral estates differing in magnitude and duration, and that they had conveyed a mineral interest that did not convert to a fixed royalty interest under a subsequent Correction Deed.
Hamilton v. Morris Res., No. 04-05-00904-CV, 2007 WL 460648 (Tex. App.–San Antonio Feb. 14, 2007).