Larsen v. Oil & Gas Conservation Commission
Wyoming Supreme Court
569 P.2d 87 (Wyo. 1977)
Relevant factsFree
The Commission (defendant) approved Apache's application to establish 80-acre drilling units over Larsen's (plaintiff) and other royalty owners' land, finding the units would protect correlative rights and prevent waste, but the order only addressed the total recoverable oil from the pool as a whole, without ever specifying the recoverable oil from each individual tract, each tract's proportional share, or the amount recoverable without waste. The district court affirmed the Commission's order, and Larsen appealed.
IssueFree
Whether the extent of correlative mineral rights must be ascertained before the government can act to protect them.