French v. Chevron

A deed's first paragraph conveyed a 1/656.17th interest in all oil, gas, and minerals under the land to Chevron's predecessor, but its second paragraph stated the conveyance was "a royalty interest only" and reserved to the grantor the rights to develop, lease, receive bonus payments, and receive delay rentals. Fuller Trust (plaintiff), successor to the original grantor, sued for a declaration that the interest granted was a royalty interest, while Chevron (defendant) argued it held a mineral interest; the trial court found a mineral interest with certain reserved rights and granted Chevron summary judgment, and Fuller Trust appealed.