Richard G. Gawenis Appellant v. Arkansas Oil & Gas Commission, and Seeco, Inc. Appellees

Summary

The court affirmed the circuit court’s approval of an agency order compulsorily integrating Gawenis’s unleased mineral interests into a natural-gas drilling unit. It held that compulsory integration was a constitutional exercise of the State’s police power rather than a compensable taking, and that Gawenis had no constitutional right to a jury trial because the order did not constitute a corporate appropriation of his property. Justice Josephine Linker Hart, dissenting, would have held that secondary-recovery methods appropriated Gawenis’s minerals and entitled him to a jury determination of full compensation.