Continental Resources of Illinois, Inc. v. Illinois Methane, LLC

Continental Resources' (plaintiff) oil and gas leases expressly excluded rights to coalbed methane trapped in coal seams or voids left by prior mining, yet Continental claimed exclusive ownership of methane trapped in mine voids beneath its leased land based on the rule of capture; Illinois Methane (defendant) collected that same coalbed methane using wells located off Continental's leased property. The lower court dismissed Continental's complaint, finding Continental had no right to the coalbed methane under its leases and that Illinois Methane's drainage was not illegal under the rule of capture.