Acoma Oil Corp. v. Wilson

Moen conveyed certain mineral interests by warranty deed without an explicit reservation. Later conveyances by the Wilsons did not mention the previously conveyed royalty interests. Acoma Oil Corp. (plaintiff) sought a declaration that its interests were not burdened by those originally conveyed royalty interests.

Whether, when a grantor conveys some mineral interests while retaining others without an explicit reservation, the conveyance is satisfied out of any interest the grantor retained.