Broughton v. Northwest Natural Gas Co.

2 Pa. D. & C.4th 226, 1988 Pa. Dist. & Cnty. Dec. LEXIS 26
CourtPennsylvania Court of Common Pleas, Crawford County
DecidedDecember 6, 1988
Docketno. EQ 1986-10
StatusPublished

This text of 2 Pa. D. & C.4th 226 (Broughton v. Northwest Natural Gas Co.) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Crawford County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Broughton v. Northwest Natural Gas Co., 2 Pa. D. & C.4th 226, 1988 Pa. Dist. & Cnty. Dec. LEXIS 26 (Pa. Super. Ct. 1988).

Opinion

THOMAS, P.J.,

ISSUES

We are called upon to determine what interest plaintiffs Broughton have in two gas wells drilled on additional defendant Hatchers’ property. The wells were drilled and managed by Northwest for a group of 25 or 30 investors. Northwest raises the issue of laches against Broughtons and files a cross-claim against Hatchers for breach of warranty or title. In summary, we must determine if Broughtons have any interest in the wells and, if so, the nature and amount of their interest. In the event of a verdict in favor of Broughtons, we must determine whether said interest should be taken from Hatchers’ one-eighth royalty interest or from Northwest’s interest. We must also consider that if Northwest is responsible to compensate Broughtons for their interest whether Northwest should be permitted to recover their loss from Hatchers under a warranty-of-title clause contained in the gas lease from Hatchers to Northwest.

We note initially that the parties and the court are again plagued by the ancient case of Dunham and [228]*228Shortt v. Kirkpatrick, 101 Pa. 36 (1882), when in 1882 the Supreme Court of Pennsylvania concluded that a reservation of “all minerals” in an agreement or deed did not include a reservation of petroleum rights. Dunham and its progeny extended this unique Pennsylvania theory to include both oil and gas. Subsequent court interpretations have established this peculiar Pennsylvania presumption to be a rebuttable one. We note that this anachronistic presumption has come before the courts of this county in recent decades for interpretation. We presume that other counties where oil and gas drillings have sprung into existence after about 1950 have been plagued with the “Dunham problem” when drafting attorneys or individuals entering into agreements, leases or conveyances which reserved mineral rights were not aware of the Dunham decision and proceeded under the nearly universal assumption that a reservation of mineral rights included reservation of oil and gas interest in the land.

We note that Edith M. Hatcher’s interest in this action has passed to her son Roger and all parties agree she has no interests to be adjudicated in this lawsuit.

CHRONOLOGICAL NARRATIVE

The genesis of the present problem began in 1964 when Broughtons conveyed the real estate at issue to Sheltons and reserved to themselves, and their heirs and assigns “an undivided one-half of all mineral rights in the above-described land.” At the time of the 1964 conveyance the land was already subject to an oil and gas lease to Earl Linn or his assignees, which had the usual provision reserving unto the lessors a one-eighth overriding royalty on [229]*229all gas in production and the right for free gas from any well for home use. This lease was subsequently renewed by Broughtons and Sheltons for an additional five years, but expired in 1974 because no drilling had been done. In 1976, Sheltons conveyed the land to Hatchers, and in 1980 Hatchers entered into a new oil and gas lease with Northwest with the usual one-eighth reserve royalty. Drilling commenced shortly after the signing of the lease and two moderately successful gas wells went into production. The cost of the two wells to Northwest and its investors amounted to some $271,000. Roger and Caroline Hatcher are divorced and each Hatcher ended up with one of the wells.

Three or four months after drilling and about the time the wells were coming into successful gas production, Broughtons learned of the drilling, contacted Northwest and inquired what they were going to do about Broughtons’ 1964 reservation of one-half of the mineral rights.

When Hatchers purchased the property their title-searching attorney apparently overlooked the Broughton mineral-rights reservation. However, before Northwest drilled, it procured a title search which disclosed Broughtons’ reservation. Northwest then conferred with potential investors and their own attorney, and decided to drill without contacting Broughtons. Hindsight shows this was an unwise decision, but in explanation thereof the president of Northwest postulated that they relied on the Dunham decision, recognizing it as an unrebuttable presumption rather than a rebuttable presumption. Further, the president of Northwest testified that at the time the drilling decision was made, Hatchers had been made aware of the “Broughton reservation” problem, and were told the title “snag” would require Northwest to escrow [230]*230some of the royalty payments. However, Northwest chose not to contact Broughtons about the title “snag” as it “might have raised more problems than it solved.”

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Dunham & Shortt v. Kirkpatrick
47 Am. Rep. 696 (Supreme Court of Pennsylvania, 1882)

Cite This Page — Counsel Stack

Bluebook (online)
2 Pa. D. & C.4th 226, 1988 Pa. Dist. & Cnty. Dec. LEXIS 26, Counsel Stack Legal Research, https://law.counselstack.com/opinion/broughton-v-northwest-natural-gas-co-pactcomplcrawfo-1988.