Richfield Oil Corp. v. Crawford

249 P.2d 600, 39 Cal. 2d 729, 1 Oil & Gas Rep. 1583, 1952 Cal. LEXIS 300
CourtCalifornia Supreme Court
DecidedOctober 21, 1952
DocketL. A. 21956
StatusPublished
Cited by51 cases

This text of 249 P.2d 600 (Richfield Oil Corp. v. Crawford) is published on Counsel Stack Legal Research, covering California Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Richfield Oil Corp. v. Crawford, 249 P.2d 600, 39 Cal. 2d 729, 1 Oil & Gas Rep. 1583, 1952 Cal. LEXIS 300 (Cal. 1952).

Opinion

TRAYNOR, J.

This appeal involves the interpretation and application to certain parcels of land of section 3600 of the Public Resources Code regulating the spacing of oil and gas wells. The accompanying diagram shows the relationship of the parcels and the wells thereon.

All oil wells are producing from the Colgrove formation in the Cuyama oil field. The dotted line across the diagram represents the Hadley-Stone fault, running in a northwest-southeast direction. This fault acts as a barrier to oil and gas and thus limits production to that portion of the Col-grove formation north and east of the fault.

All of the property is owned by H. S. Russell. In 1945 he leased the property to the Norris Oil Company. Subsequently in 1945, Norris subleased parcels two and three to predecessors in interest of plaintiff Richfield Oil Corporation. In 1947 Norris subleased parcels one and four to Carpenter and Henderson, plaintiffs in intervention. In 1948 Carpenter and Henderson subleased parcels one and four to Anderson *733 Associates who in turn assigned an undivided half-interest therein to Richfield. Shortly thereafter Anderson Associates and Richfield quitclaimed all their interest in parcel four to Carpenter and Henderson. In June, 1949, Carpenter and Henderson subleased parcel four to defendants Crawford and Hiles. Since July 25, 1949, defendants have been producing oil from Well 1. The surface location of this well is more than 200 feet from the boundaries of parcel four, but its producing interval or bottom is in oil producing land northeast of the fault, less than 100 feet from the boundaries of defendants’ property. Richfield is sublessee under oil and gas leases for parcels one, two, and three, and is producing oil from Wells 88, 187, 18 and 11 on those parcels.

Richfield sought to enjoin operation of Well 1 and recover damages for its past operations on two theories: that the well was operated in violation of Public Resources Code, section 3600, and that it constituted a subsurface trespass on Rich-field’s property. In a third action Richfield sought a declaration as to the location of the boundary between the parcels in relation to the subsurface location of Well 1. Plaintiffs in intervention, Carpenter and Henderson, sought declaratory relief to have their rights declared respecting royalty interests in Well 1. The trial court denied Richfield injunctive and monetary relief, declared that the well was entirely within defendants ’ property, and declared that Carpenter and Henderson owned 23 per cent of the production of Well 1 and that Richfield had no interest therein. Richfield appeals from the judgment.

Construction of Section 3600

Section 3600 provides that “any well hereafter drilled for oil or gas, or hereafter drilled and permitted to produce oil or gas, which is located within 100 feet of an outer boundary of the parcel of land on which the well is situated, or within 100 feet of a public street or road or highway dedicated prior to the commencement of drilling of the well, or within 150 feet of either a well being drilled or a well theretofore drilled which is producing oil or gas or a well which has been drilled and is not producing but which is capable of producing oil or gas, is a public nuisance.” Richfield contends that Well 1 is a public nuisance, on the ground that it “is located within 100 feet of an outer boundary of the parcel of land on which the well is situated.” Richfield concedes that the surface location of Well 1 is more than 100 feet from the boundary, *734 but contends that the statute is violated when the producing interval of a well is less than 100 feet from the boundary. Defendants contend that section 3600 restricts only the surface location of oil wells and does not apply to the producing intervals thereof.

Richfield urges that ‘‘ well ’’ is commonly understood to mean the entire shaft from the surface of the earth to the oil pool below and that in oil leases “boundary” usually includes “underground boundary.” (See Federal Oil Co. v. Brower, 36 Cal.2d 367, 370 [224 P.2d 4].) Defendants urge on the other hand that the word “located” usually refers only to wells on the surface of the ground (see Union Pac. R.R. Co. v. City of Los Angeles, 53 Cal.App.2d 825, 829 [128 P.2d 408]) and that the words “on which the well is situated” indicate that the statute regulates wells “on” a parcel as opposed to wells “in or under” a parcel. (Cf. Richter v. Adams, 43 Cal.App.2d 184, 187 [110 P.2d 486].) The word “well,” or any other word in section 3600, cannot be disassociated from its contest or the oil well spacing legislation as a whole. Thus, in section 3602 the contest shows that “well” means the surface location, for the phrase therein “placed as to be as far from the lateral boundary lines of the parcel of land as the configuration of the surface and the esisting improvements thereon will permit” could have no reference to the entire length of the shaft. Our inquiry into the proper interpretation of section 3600 cannot be guided solely by the dictionary meaning of each word standing alone; we must consider the well spacing legislation as a whole to determine the meaning of section 3600. (People v. Moroney, 24 Cal.2d 638, 642 [150 P.2d 888] ; Myers v. Alta Construction Co., 37 Cal.2d 739, 742 [235 P.2d 1].)

Comparison of section 3600 with other sections of the well spacing legislation supports defendants’ interpretation. Thus section 3606, providing for the location of wells when the surface of the land is unsuitable for drilling, permits slant drilling into a parcel containing an acre or more when all or substantially all of the surface of such parcel is unsuitable for surface location of a well. This section also provides that in such cases the producing interval must be located not less than 75 feet from the outer boundary of the parcel into which it is drilled and that the surface location must be not less than 25 feet from the outer boundary of the parcel into which it is drilled. Section 3606 finally provides that *735 “to enforce the provisions of this section” the State Oil and Gas Supervisor may require the operator to make a subsurface directional survey of the well and to file a plat of such survey with the supervisor, which is open- to public inspection.

Section 3600, however, does not provide that a subsurface survey may be required by the supervisor. Under Richfield’s interpretation, although the Legislature has given the supervisor ample power to enforce part of the well spacing legislation, it fails to provide him with one of the most effective means of discovering violations of another part thereof. 1 If the Legislature intended enforcement of section 3600 to be left to action by private parties (as in the present ease), difficulties remain.

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

Related

People v. Morgan
California Supreme Court, 2026
Parsonage v. Wal-Mart Associates
California Court of Appeal, 2026
Ostrander v. Callahan CA3
California Court of Appeal, 2024
Southfork Ranch v. Bunn CA2/6
California Court of Appeal, 2020
Bloxham v. Saldinger
228 Cal. App. 4th 729 (California Court of Appeal, 2014)
Harris v. City of Santa Monica
294 P.3d 49 (California Supreme Court, 2013)
People v. Licas
159 P.3d 507 (California Supreme Court, 2007)
Thornton v. Carlson
4 Cal. App. 4th 1249 (California Court of Appeal, 1992)
Penasquitos, Inc. v. Superior Court
812 P.2d 154 (California Supreme Court, 1991)
California Financial Responsibility Co. v. Pierce
226 Cal. App. 3d 1663 (California Court of Appeal, 1991)
Steelgard, Inc. v. Jannsen
171 Cal. App. 3d 79 (California Court of Appeal, 1985)
Allis-Chalmers Corp. v. City of Oxnard
126 Cal. App. 3d 814 (California Court of Appeal, 1981)
Kopp v. State
595 P.2d 309 (Idaho Supreme Court, 1979)
Estate of Trego
81 Cal. App. 3d 530 (California Court of Appeal, 1978)
Allen v. California Toll Bridge Authority
68 Cal. App. 3d 340 (California Court of Appeal, 1977)
Topps & Trowsers v. Superior Court
31 Cal. App. 3d 102 (California Court of Appeal, 1973)
Martin v. Tucker
300 A.2d 480 (Supreme Court of Rhode Island, 1973)
Dougall v. Sateren
203 N.W.2d 789 (South Dakota Supreme Court, 1973)
People v. Rogers
486 P.2d 129 (California Supreme Court, 1971)
Flournoy v. Kirshbaum
268 Cal. App. 2d 155 (California Court of Appeal, 1968)

Cite This Page — Counsel Stack

Bluebook (online)
249 P.2d 600, 39 Cal. 2d 729, 1 Oil & Gas Rep. 1583, 1952 Cal. LEXIS 300, Counsel Stack Legal Research, https://law.counselstack.com/opinion/richfield-oil-corp-v-crawford-cal-1952.