Browne v. Artex Oil Co.

2021 Ohio 2239
CourtOhio Court of Appeals
DecidedJune 30, 2021
Docket21CA000002
StatusPublished
Cited by2 cases

This text of 2021 Ohio 2239 (Browne v. Artex Oil Co.) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Browne v. Artex Oil Co., 2021 Ohio 2239 (Ohio Ct. App. 2021).

Opinion

[Cite as Browne v. Artex Oil Co., 2021-Ohio-2239.]

COURT OF APPEALS GUERNSEY COUNTY, OHIO FIFTH APPELLATE DISTRICT

JUDGES: BARRY BROWNE, ET AL : Hon. Craig R. Baldwin, P.J. : Hon. W. Scott Gwin, J. Plaintiffs-Appellants : Hon. Earle E. Wise, J. : -vs- : : Case No. 21CA000002 ARTEX OIL COMPANY, ET AL : : Defendants-Appellees : OPINION

CHARACTER OF PROCEEDING: Civil appeal from the Guernsey County Court of Common Pleas, Case No. 14-OG- 513

JUDGMENT: Affirmed

DATE OF JUDGMENT ENTRY: June 30, 2021

APPEARANCES:

For Plaintiffs-Appellants For Defendants-Appellees

ETHAN VESSELS DANIEL CORCORAN Field, Dehmlow & Vessels, LLC Theisen Brock, LPA 309 Second Street 424 Second Street Marietta, OH 45750 Marietta, OH 45750 [Cite as Browne v. Artex Oil Co., 2021-Ohio-2239.]

Gwin, J.,

{¶1} Appellants Barry L. Browne and Rose R. Browne appeal the January 21,

2021 judgment entry of the Guernsey County Court of Common Pleas granting summary

judgment to appellees Artex Oil Company, Artex Energy Group, LLC, Arloma Corporation,

and James Huck, LLC.

Facts & Procedural History

{¶2} Appellants own approximately eighty-six acres located in Guernsey

County, Ohio, along with the oil and gas interests underlying the property. They

purchased the property in 2012. Appellants’ predecessor in title, Mary Mercer, entered

into an oil and gas lease on December 20, 1975, recorded on January 26, 1976. The

lease created a primary lease term of one year, and contained a habendum clause which

provided an extension of the one-year term “long thereafter as oil and gas, or either of

them, is produced by lessee from said land or from a communized unit as hereinafter

provided.”

{¶3} Pursuant to the lease, one well was drilled on the property known as the

Mercer No. 1 Well, commenced during the one-year primary term and completed on

February 17, 1977. The Mercer well was originally drilled by Mammoth Producing

Corporation (“Mammoth”).

{¶4} Appellees acquired interests in the lease through various assignments,

cross-assignments, and stipulations of interest. Artex has operated the well since 1999.

Artex’s records state that from December 1999 through September 2014, the well

produced 1,771.49 barrels of oil, which generated gross revenue of more than $100,000. Guernsey County, Case No. 21CA000002 3

Artex presented evidence in 2016 that it paid royalties to appellants in 2013, 2014, and

2015.

{¶5} On December 1, 2014, appellants filed a complaint against appellees for

quiet title, declaratory judgment, intentional conversion, and unjust enrichment, all based

upon their contention that the lease had terminated by its terms due to lack of production.

The complaint alleged that the Mercer well did not produce any oil or gas for a sufficient

amount of time to terminate the lease.

{¶6} On December 15, 2014, appellees filed an answer asserting, in part, a

statute of limitations defense, and filed a counterclaim for declaratory judgment, claiming

the lease was valid and enforceable because the well had been continuously producing

since 1977.

{¶7} On July 15, 2015, appellees filed a motion for summary judgment, claiming

continuous production of oil from the well. The trial court denied the motion on August

26, 2015.

{¶8} Appellants filed a motion for summary judgment on January 15, 2016,

arguing the lease was void because there was no evidence of production from 1981 to

2000 and there were substantial periods of non-production from 1999 to the present.

Appellees filed a second motion for summary judgment on January 19, 2016, again

claiming continuous production. The trial court denied both motions after holding a

hearing.

{¶9} On June 27, 2017, appellees filed a motion for reconsideration based on

new case law. On June 29, 2017, appellants also filed a motion for reconsideration based Guernsey County, Case No. 21CA000002 4

on new case law. The trial court granted appellees’ motion for reconsideration and motion

for summary judgment, finding the lease was valid and enforceable.

{¶10} Appellants appealed to this Court, arguing the following: the trial court erred

when it held appellants’ claims were barred by a 15 year statute of limitations; the trial

court erred when it determined that the burden of proof rests with appellants when seeking

declaratory judgment to terminate an oil and gas lease for lack of production in paying

quantities; the trial court erred when it held that production records and affidavits can be

used to evidence production; and the trial court erred when it determined that the plaintiffs’

were seeking to prove the well was no longer profitable, when the plaintiffs’ case was

based on a question of non-production of oil.

{¶11} In Browne v. Artex Oil Co., 5th Dist. Guernsey No. 17 CA 20, 2018-Ohio-

3746, we overruled appellants’ assignments of error and affirmed the decision of the trial

court.

{¶12} Appellants appealed to the Ohio Supreme Court, requesting the Supreme

Court accept the following propositions of law: in an action to declare that an oil and gas

lease has terminated under its own terms for lack of production in paying quantities, the

applicable statute of limitations is 21 years; a cessation of commercial production of oil or

gas, generally for two years or more, will cause an oil and gas lease to automatically

terminate under the terms of its habendum clause; in order to perpetuate an oil and gas

lease under its habendum clause, there must exist objective and verifiable evidence of

the commercial sale of oil or gas; evidence of production is not the equivalent to evidence

of production in paying quantities necessary to perpetuate an oil and gas lease under its

habendum clause; in an action to declare that an oil and gas lease has expired under its Guernsey County, Case No. 21CA000002 5

own terms for lack of production in paying quantities, the burden of proof is on the lessee;

and, in an action to declare that an oil and gas lease has expired under its own terms for

lack of production in paying quantities, when deciding a motion for summary judgment

filed by the lessee, a trial court must construe all of the evidence in a light most favorable

to the lessor.

{¶13} The Ohio Supreme Court accepted only appellants’ first proposition of law

and rejected the balance of appellants’ propositions of law. Thus, the single question

before the Court was which statute of limitations applied to appellants’ claim that the lease

terminated by its terms and by operation of law. The Court held that appellants’ claims

are governed by the 21-year statute of limitations, reversed our decision, and remanded

the matter to the trial court to evaluate the parties’ claims in light of the correct statute of

limitations.

{¶14} Upon remand to the trial court, the trial court permitted the parties to conduct

further discovery. Appellees filed a motion for summary judgment on January 10, 2020.

Appellants filed their own motion for summary judgment on October 15, 2020. The parties

filed numerous responses and replies, including supplemental memoranda in support of

their motions.

{¶15} The trial court issued a judgment entry on January 21, 2021, granting

appellees’ motion for summary judgment and denying appellants’ motion for summary

judgment. The trial court dismissed appellants’ complaint with prejudice, finding they

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

Related

Cite This Page — Counsel Stack

Bluebook (online)
2021 Ohio 2239, Counsel Stack Legal Research, https://law.counselstack.com/opinion/browne-v-artex-oil-co-ohioctapp-2021.