Tri M Petroleum Co. v. Getty Oil Co.; Ridgway v. Shell Oil Co.
United States Court of Appeals for the Fifth Circuit
792 F.3d 558 (5th Cir. 1986)
In two consolidated cases, state oil and gas boards ordered forced pooling of tracts including leaseholds held by Getty (defendant) and Shell (defendant), and after other operators drilled wells within the pooled units (but not directly on the Getty or Shell leaseholds, and despite Getty and Shell declining to participate in drilling costs or farm out their interests), the primary terms of the Getty and Shell leases expired; the top-lease holder Tri M and lessor Ridgway (plaintiffs) sued to cancel the leases, but the district courts in both cases declined to cancel them because of the pooled-unit drilling.
Whether drilling within a pooled unit created by a state commission's forced-pooling order extends oil and gas leases on all lands located inside the unit.