Oil Valley Petroleum v. Moore

Summary

The court vacated the intermediate appellate decision, reversed the trial court's partial summary adjudication for Moore, and remanded for further equitable proceedings. It held that Moore's summary-judgment evidence did not establish that the well was commercially profitable, and that a lessee's surrender may extinguish an overriding royalty interest unless the surrender resulted from fraud or breach of fiduciary duty. The court declined to decide the parties' competing title and equitable claims in the first instance because the factual record was undeveloped. It also held that prevailing-party status for attorney-fee purposes must be determined in the trial court.