Enron Oil & Gas Company v. Worth
Oklahoma Court of Civil Appeals
947 P.2d 610 (Okla. Civ. App. 1997)
Virgil Worth (defendant) owned the surface of a tract whose mineral estate was owned by a separate third party, who granted Enron Oil & Gas (plaintiff) permits to conduct seismic exploration on the property; Worth refused to allow Enron onto his surface land, and the trial court ruled that mineral owners could not sever the exploration right from the broader mineral estate's development and production rights, invalidating Enron's permits.
Whether the owner of an unleased, undivided mineral interest may authorize a third party to enter onto the surface of land owned by another to conduct geophysical exploration, without conveying the other rights comprising the mineral estate, such as the right to develop and produce the minerals.