Garza v. Prolithic Energy Co., L.P.

The Saenzes conveyed fixed mineral and royalty fractions to Claypool (one-half) and Lee (fifteen-thirty-seconds) under deeds subject to an existing lease reserving a one-eighth royalty, with future-lease clauses describing their interests in terms of that customary one-eighth royalty fraction. When the original lease ended and a new lease reserved a larger one-fifth royalty, Claypool and Lee claimed their full fixed fractional share (one-half and fifteen-thirty-seconds, respectively) of the new, larger royalty, while the Saenzes argued the future-lease clauses fixed their interests at a smaller, capped amount tied to the old one-eighth royalty regardless of what any new lease reserved. The trial court granted Claypool and Lee summary judgment.