Springer Ranch, Ltd. v. Jones

Subdivision co-owners Springer (plaintiff) and Sullivan (defendant) contracted that royalties from any well would be paid to the surface-estate owner "on which" the well "was situated," originally covering only vertical wells; twenty years later, a new horizontal well's surface wellhead sat on Springer's tract but its underground drainhole extended into the ground beneath Sullivan's tract, and the trial court ruled royalties should follow the location of the well's actual producing portions.