Summaries of Civil Opinions and Published Criminal Opinions Issued - Week of February 11, 2013

NOTE: Summaries are prepared by the court's staff attorneys and law clerks for public information only and reflect his or her interpretation alone of the facts and legal issues. The summaries are not part of the court's opinion in the case and should not be cited to, quoted, or relied upon as the opinion of the court.

Links to full text of opinions (PDF version) can be accessed by clicking the cause number.

Bradshaw v. Steadfast Fin., L.L.C., No. 02-10-00369-CV (Feb. 14, 2013) (McCoy, J., joined by Livingston, C.J., and Gabriel, J.).

Held: The level of duty owed by the executive rights holder depends on the amount of control placed in his or her hands by the terms of the NPRI reservation itself—i.e., whether a "fraction of royalty" or a "fractional royalty" is reserved. Because Appellant's NPRI is a fraction of royalty, see Range Res. Corp. v. Bradshaw, 266 S.W.3d 490, 497-98 (Tex. App.—Fort Worth 2008, pet. denied) (op. on reh'g), Appellee Steadfast owed her a "fiduciary" duty as that duty is understood in oil and gas law.

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