Corban v. Chesapeake Exploration, LLC

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Plaintiff filed this action against Defendants seeking to quiet title to oil and gas rights under his surface lands and requesting a declaratory judgment, a permanent injunction, and compensation for conversion. The federal district court concluded that its ruling on the parties’ motions for summary judgment required a clarification of two areas of Ohio law and certified these questions to the Supreme Court. The Supreme Court answered (1) the 2006 version of the Dormant Mineral Act, rather than the 1989 version of the Act, applies to all claims asserted after June 30, 2006 alleging that the rights to minerals vested in the surface land holder prior to the 2006 amendments as a result of abandonment; and (2) a payment of a delay rental during the primary of an oil and gas lease is neither a title transaction nor a savings event under the Act. View "Corban v. Chesapeake Exploration, LLC" on Justia Law