Mcardle Family Partnership v. Antero Resources Corporation

CourtCourt of Appeals for the Fourth Circuit
DecidedApril 20, 2026
Docket25-1624
StatusUnpublished

This text of Mcardle Family Partnership v. Antero Resources Corporation (Mcardle Family Partnership v. Antero Resources Corporation) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fourth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mcardle Family Partnership v. Antero Resources Corporation, (4th Cir. 2026).

Opinion

USCA4 Appeal: 25-1624 Doc: 46 Filed: 04/20/2026 Pg: 1 of 8

UNPUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 25-1624

MCARDLE FAMILY PARTNERSHIP, a Pennsylvania Limited Partnership, individually and on behalf of others similarly situated,

Plaintiff – Appellant,

v.

ANTERO RESOURCES CORPORATION, a Delaware corporation; KEY OIL COMPANY, a West Virginia corporation; FRANKLIN L. BUTLER, an individual,

Defendants – Appellees.

Appeal from the United States District Court for the Northern District of West Virginia, at Clarksburg. Thomas S. Kleeh, Chief District Judge. (1:22-cv-00001-TSK)

Argued: January 27, 2026 Decided: April 20, 2026

Before GREGORY, RICHARDSON, and RUSHING, Circuit Judges.

Affirmed in part, vacated in part, and remanded by unpublished opinion. Judge Rushing wrote the opinion, in which Judge Gregory and Judge Richardson joined.

ARGUED: Frank Edward Simmerman III, SIMMERMAN LAW OFFICE, PLLC, Clarksburg, West Virginia, for Appellant. Amy Marie Smith, STEPTOE & JOHNSON PLLC, Bridgeport, West Virginia, for Appellees. ON BRIEF: Lauren K. Turner, McKenna E. Meadows, STEPTOE & JOHNSON PLLC, Bridgeport, West Virginia, for Appellees. USCA4 Appeal: 25-1624 Doc: 46 Filed: 04/20/2026 Pg: 2 of 8

Unpublished opinions are not binding precedent in this circuit.

2 USCA4 Appeal: 25-1624 Doc: 46 Filed: 04/20/2026 Pg: 3 of 8

RUSHING, Circuit Judge:

The McArdle Family Partnership (MFP) claims it owns mineral royalty interests in

certain West Virginia oil and gas leasehold estates. It alleges that Defendants—Antero

Resources Corporation, Key Oil Company, and Franklin L. Butler—breached their

contract by failing to pay MFP those royalties. The district court granted summary

judgment to Defendants on MFP’s breach of contract claim and denied MFP’s cross-

motion for summary judgment. We affirm in part, vacate in part, and remand.

I.

In Count II of the operative complaint, MFP claims that, by assignment from James

Drilling Corporation dated May 5, 2008, MFP became vested with the following interests

in West Virginia oil and gas leasehold estates: (1) a 1/32 overriding royalty interest in the

Towner lease; (2) a 1/32 overriding royalty interest in the Stone lease; and (3) a 1/64 net

profits interest in the Hudson leases. 1 An overriding royalty interest is “[a] share of either

production or revenue from production (free of the costs of production) carved out of a

lessee’s interest under an oil-and-gas lease.” Royalty, Black’s Law Dictionary (12th ed.

2024). A net profits interest is “[a] share of production free of the costs of production . . . .

[U]nlike a royalty, it is payable only if there is a net profit, and the costs that are used to

calculate the net profit depend on what is negotiated.” Net-Profits Interest, Black’s Law

1 On appeal, by contrast, MFP claims a 1/64 overriding royalty interest in the Towner lease. MFP also argues it possesses a 1/16 overriding royalty interest in production from the Hudson property, which appears to be the subject of a different count in the complaint. Because the district court’s grant of summary judgment to Defendants on Count II is the sole issue before us on appeal, we consider only the interests alleged in Count II. 3 USCA4 Appeal: 25-1624 Doc: 46 Filed: 04/20/2026 Pg: 4 of 8

Dictionary (12th ed. 2024). MFP alleges that Defendants breached their contract by failing

to pay royalties according to those interests.

The district court granted summary judgment to Defendants on Count II and denied

MFP’s cross-motion for summary judgment. McArdle Fam. P’ship v. Antero Res. Corp.,

No. 1:22-cv-01, 2024 WL 1349200, at *7–8 (N.D. W. Va. Mar. 29, 2024). The court held

that MFP does not own the claimed interests because they were conveyed to Key Oil in

1996, long before James Drilling Corporation allegedly conveyed them to MFP in 2008.

Id. at *7. Specifically, the court considered a May 30, 1996 assignment from James

Drilling Corporation, James I. Shearer, and Beatrice E. Shearer to Key Oil. Id. at *3, 5–6.

The court concluded that the 1996 assignment was “a clear, broad conveyance” of all of

the assignors’ interests in the relevant leases, without exceptions or reservations. Id. at *3.

In the alternative, the court reasoned that “even if the grant in the 1996 assignment was not

broad and without exceptions . . . , the interests could not have been reserved” because they

were extinguished by the doctrine of merger. Id. at *7.

We dismissed MFP’s first appeal for lack of jurisdiction. McArdle Fam. P’ship v.

Antero Res. Corp., No. 24-1347, 2025 WL 1167651 (4th Cir. Jan. 31, 2025). On MFP’s

motion, the district court then entered final judgment on Count II pursuant to Federal Rule

of Civil Procedure 54(b). MFP appealed again, and we now have jurisdiction under 28

U.S.C. § 1291.

II.

“We review the district court’s ruling on cross-motions for summary judgment de

novo.” Young v. Equinor USA Onshore Props., Inc., 982 F.3d 201, 205 (4th Cir. 2020).

4 USCA4 Appeal: 25-1624 Doc: 46 Filed: 04/20/2026 Pg: 5 of 8

Summary judgment is warranted “if the movant shows that there is no genuine dispute as

to any material fact and the movant is entitled to judgment as a matter of law.” Fed. R.

Civ. P. 56(a).

“We also review de novo the district court’s contract interpretation underlying its

summary judgment ruling.” Young, 982 F.3d at 205–206. The parties agree that West

Virginia law applies. See Francis v. Allstate Ins. Co., 709 F.3d 362, 369 (4th Cir. 2013)

(“A federal court sitting in diversity is required to apply the substantive law of the forum

state, including its choice-of-law rules.”).

III.

This appeal raises a question of contract interpretation. See Syl. Pt. 3, Faith United

Methodist Church & Cemetery of Terra Alta v. Morgan, 745 S.E.2d 461 (W. Va. 2013)

(“Deeds are subject to the principles of interpretation and construction that govern

contracts generally.”). Under West Virginia law, when a real estate conveyance includes

“no words of limitation,” “such conveyance operates to pass the fee simple or the whole

estate or interest, legal or equitable, which the grantor had power to dispose of in such real

property unless a contrary intention appears in such conveyance.” Syl. Pt. 3, Meadows v.

Belknap, 483 S.E.2d 826 (W. Va. 1997) (internal quotation marks omitted). “‘In order to

create an exception or reservation in a deed which would reduce a grant in a conveyance

clause which is clear, correct and conventional, such exception or reservation must be

expressed in certain and definite language.’” Syl. Pt. 2, DWG Oil & Gas Acquisitions, LLC

v. S. Country Farms, Inc., 796 S.E.2d 201 (W. Va. 2017) (quoting Syl. Pt. 2, Hall v.

Hartley, 119 S.E.2d 759 (W. Va. 1961)).

5 USCA4 Appeal: 25-1624 Doc: 46 Filed: 04/20/2026 Pg: 6 of 8

We agree with the district court that the 1996 assignment was a clear, broad

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Related

Thomas Francis v. Allstate Insurance Company
709 F.3d 362 (Fourth Circuit, 2013)
Faith United Methodist Church & Cemetery of Terra Alta v. Morgan
745 S.E.2d 461 (West Virginia Supreme Court, 2013)
Hall v. Hartley
119 S.E.2d 759 (West Virginia Supreme Court, 1961)
Meadows v. Belknap
483 S.E.2d 826 (West Virginia Supreme Court, 1997)
DWG Oil & Gas Acquisitions, LLC v. Southern Country Farms, Inc.
796 S.E.2d 201 (West Virginia Supreme Court, 2017)
Travis Young v. Equinor USA Onshore Properties
982 F.3d 201 (Fourth Circuit, 2020)

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Mcardle Family Partnership v. Antero Resources Corporation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mcardle-family-partnership-v-antero-resources-corporation-ca4-2026.