City of Crowley, Texas v. TotalEnergies E&P USA, Inc., TotalEnergies E&P Barnett USA, LLC, TotalEnergies E&P USA Barnett 1, LLC, and TotalEnergies E&P USA Barnett 2, LLC

CourtCourt of Appeals of Texas
DecidedJuly 17, 2025
Docket02-24-00088-CV
StatusPublished

This text of City of Crowley, Texas v. TotalEnergies E&P USA, Inc., TotalEnergies E&P Barnett USA, LLC, TotalEnergies E&P USA Barnett 1, LLC, and TotalEnergies E&P USA Barnett 2, LLC (City of Crowley, Texas v. TotalEnergies E&P USA, Inc., TotalEnergies E&P Barnett USA, LLC, TotalEnergies E&P USA Barnett 1, LLC, and TotalEnergies E&P USA Barnett 2, LLC) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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City of Crowley, Texas v. TotalEnergies E&P USA, Inc., TotalEnergies E&P Barnett USA, LLC, TotalEnergies E&P USA Barnett 1, LLC, and TotalEnergies E&P USA Barnett 2, LLC, (Tex. Ct. App. 2025).

Opinion

In the Court of Appeals Second Appellate District of Texas at Fort Worth ___________________________ No. 02-24-00088-CV ___________________________

CITY OF CROWLEY, TEXAS, Appellant

V.

TOTALENERGIES E&P USA, INC.; TOTALENERGIES E&P BARNETT USA, LLC; TOTALENERGIES E&P USA BARNETT 1, LLC; AND TOTALENERGIES E&P USA BARNETT 2, LLC; Appellees

On Appeal from the 96th District Court Tarrant County, Texas Trial Court No. 096-000003-15

Before Kerr, Birdwell, and Walker, JJ. Memorandum Opinion by Justice Birdwell MEMORANDUM OPINION

This gas-royalty dispute turns on a single question of contract interpretation:

Does the parties’ mineral lease (the Lease) require the relevant gas-royalty payment to

be calculated based on the market value of the gas at the point of sale—here, the

wellhead—or based on the combined sum of the wellhead market value plus post-sale

postproduction costs?

Appellant City of Crowley, Texas (Lessor) advanced the latter interpretation,

but Appellees TotalEnergies E&P USA, Inc.; TotalEnergies E&P Barnett USA, LLC;

TotalEnergies E&P USA Barnett 1, LLC; and TotalEnergies E&P USA Barnett 2,

LLC (Lessees)1 advanced the former, and all parties moved for summary judgment on

the issue. Lessor argued that, because the wellhead sales price was tied to the third-

party buyer’s post-sale postproduction costs and downstream proceeds, Lessees

effectively “realize[d] proceeds of production after deduction for

[postproduction] . . . expense[s]” within the meaning of the Lease, and thus, under the

Lease’s terms, “the deductions [must] be added” to the gas’s wellhead market value

for purposes of the royalty calculation. Lessees disagreed, pointing out that there were

no postproduction expenses prior to the point of sale—the wellhead—so there was

1 TotalEnergies E&P USA Barnett 1, LLC and TotalEnergies E&P USA Barnett 2, LLC are the two current co-lessees. TotalEnergies E&P USA, Inc. is a former lessee; it conveyed its interest to TotalEnergies E&P Barnett 2, LLC in 2020. TotalEnergies E&P Barnett USA, LLC, meanwhile, is the lease operator. Nonetheless, all four entities’ fates rise and fall on the same legal argument, so for ease of reference, we refer to them collectively as Lessees.

2 nothing to “deduct[]” and no “deductions [to] be added” to the “realize[d] proceeds.”

The trial court agreed with Lessees, and Lessor, in its sole appellate issue, seeks our

review of the interpretive question.

This question is rendered significantly easier by the fact that we have answered

it before in a substantially similar context. In Shirlaine, we interpreted nearly identical

lease language, and we held that because the lease unambiguously “fixe[d] the

wellhead as the valuation point” for the royalty, no royalty was due on post-sale

postproduction costs—the lessee was not “realiz[ing] proceeds of production after

deduction for [postproduction] . . . expenses.” Shirlaine W. Props. Ltd. v. Jamestown Res.,

L.L.C., No. 02-18-00424-CV, 2021 WL 5367849, at *1, *6 (Tex. App.—Fort Worth

Nov. 18, 2021, pet. denied) (mem. op.). Although Lessor attempts to distinguish

Shirlaine by arguing that a separate provision unique to the present Lease converts the

wellhead-market-value royalty into a market-value-plus royalty, its attempts are

unsuccessful; Shirlaine is on point, binding, and sound. Cf. Devon Energy Prod. Co. v.

Sheppard, 668 S.W.3d 332, 348 (Tex. 2023) (interpreting leases and holding that the

leases were “‘proceeds plus’ leases that employ[ed] a two-prong calculation of the

royalty base”).

Because the trial court’s summary judgment aligns with Shirlaine, we will affirm.

I. Background

A royalty payment represents a lessor’s fractional share of mineral production

from a lease. BlueStone Nat. Res. II, LLC v. Randle, 620 S.W.3d 380, 386–87 (Tex.

3 2021). Generally, the amount of the royalty payment turns on how the production is

valued—the valuation “yardstick[,] e.g., market value, proceeds, price” and “the

location for measuring the yardstick[,] e.g., at the well, at the point of sale.’” Id. at 387.

The valuation yardstick and location are often intertwined, and in the absence of an

agreement to the contrary, these parameters often dictate whether the royalty is

burdened by postproduction costs, i.e., the costs incurred to prepare the minerals for

downstream sale. See id. at 386–90; see Burlington Res. Oil & Gas Co. v. Tex. Crude Energy,

LLC, 573 S.W.3d 198, 203 (Tex. 2019) (clarifying that the term “postproduction

costs” refers “to processing, compression, transportation, and other costs expended

to prepare raw oil or gas for sale at a downstream location”).

If a royalty is based on gas’s market value at the wellhead, then the value is

determined “before [the gas] is transported, treated, compressed or otherwise

prepared for market.” Heritage Res., Inc. v. NationsBank, 939 S.W.2d 118, 125, 129 (Tex.

1996) (Owen, J.) (plurality op. on reh’g);2 see BlueStone, 620 S.W.3d at 388–89. But even

though postproduction occurs beyond the point of valuation, the wellhead royalty is

considered to bear its share of postproduction costs because the market value at the

wellhead can be—and frequently is—estimated by taking the downstream market

price and subtracting the postproduction costs incurred between the wellhead and

that point. See Carl v. Hilcorp Energy Co., 689 S.W.3d 894, 896 (Tex. 2024) (noting that

See BlueStone, 620 S.W.3d at 388 n.29 (explaining how Justice Owen’s 2

concurring opinion became the plurality opinion on rehearing and citing it as such).

4 “[o]ften, . . . minerals are not sold until after post-production” so “the workback

method permits an estimation of wellhead market value by using the proceeds of a

downstream sale and subtracting postproduction costs”); BlueStone, 620 S.W.3d at

388–89 (noting that “[w]hen comparable sales data is unavailable, . . . the ‘net-back’ or

‘workback’ method” provides “an estimation of wellhead market value”); Burlington,

573 S.W.3d at 206–07 (clarifying that “a wellhead valuation point . . . generally

requires the royalty holder to bear post[]production costs”); Heritage, 939 S.W.2d at

130 (Owen, J.) (plurality op. on reh’g) (noting that market value “can be proven by the

so-called net-back approach, which determines the prevailing market price at a given

point and backs out the necessary, reasonable costs between that point and the

wellhead”).

But if the valuation yardstick is gross proceeds, then “the valuation point is

necessarily the point of sale because that is where the gross is realized or received.”

BlueStone, 620 S.W.3d at 391. The relevant inquiry is the amount the lessee actually

receives for the minerals, regardless of whether that amount is the market value. Id. at

389. And when the sale occurs at a point downstream from the wellhead—after at

least some postproduction has occurred—then the gross-proceeds royalty is free from

postproduction costs, meaning that the royalty holder “share[s] in the enhanced value

of production but not the expenses incurred to make it so.” Sheppard, 668 S.W.3d at

336–37, 348 (noting that “gross proceeds . . . by definition must be free of

postproduction costs”).

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Related

Judice v. Mewbourne Oil Co.
939 S.W.2d 133 (Texas Supreme Court, 1996)
Heritage Resources, Inc. v. NationsBank
939 S.W.2d 118 (Texas Supreme Court, 1997)
Gordon Potts v. Chesapeake Exploration, L.L
760 F.3d 470 (Fifth Circuit, 2014)

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City of Crowley, Texas v. TotalEnergies E&P USA, Inc., TotalEnergies E&P Barnett USA, LLC, TotalEnergies E&P USA Barnett 1, LLC, and TotalEnergies E&P USA Barnett 2, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/city-of-crowley-texas-v-totalenergies-ep-usa-inc-totalenergies-ep-texapp-2025.