N.d. Energy Services v. Lime Rock Resources Iii-A

Summary

The court affirmed summary judgment for Lime Rock, holding that its oil and gas leases authorized the reasonable use of layflat hoses to transport water for fracking. The court also held that a recorded memorandum gave ND Energy constructive notice of the preexisting surface use agreement, defeating good-faith purchaser status. Because Lime Rock had preexisting rights to use the property, its conduct was justified and ND Energy's interference and injunction claims failed.