On May 23, 2025, the Texas Supreme Court issued a long-awaited opinion in Cromwell v. Anadarko E&P Onshore, LLC, in which it held that two habendum clauses written in the passive voice did not specifically require production by the lessee, but instead could be perpetuated by production from anyone on the leased premises.
Continue Reading Not All Lessees Must Produce, According to New Texas Supreme Court Opinion Rejecting Washout
