Premier Oil & Gas v. Welch

Summary

The New Mexico Supreme Court affirmed the Court of Appeals, holding that Premier Oil & Gas, Inc. is a bona fide purchaser of mineral rights despite the 2007 Heirship Judgment being void for lack of jurisdiction. The Court ruled that a purchaser may rely on a facially regular judgment and that extrinsic evidence of jurisdictional defects cannot defeat BFP status. It also affirmed that the issue is a question of law reviewed de novo.