Short v. Texaco, Inc.

Indiana's Mineral Lapse Act automatically terminated mineral interests unused for 20 years, defining 'use' broadly to include actual production, preservation payments, or filed claims, reverting lapsed interests to the surface landowner, with a two-year grace period after enactment for existing interest-holders to renew; the trial court declared the Act void, reasoning it violated due process by not requiring individualized notice before termination, and Short (plaintiff, as enforcement party) sought review.

Whether Indiana's Mineral Lapse Act violates constitutional due process or equal protection requirements.