Wagner & Brown, Ltd. v. Sheppard

Sheppard (plaintiff) leased her mineral interest to CWRI, which entered a pooling agreement (operated by Wagner & Brown) covering her tract along with adjacent ones. Her lease provided for termination if royalties were not paid within 120 days of production, and that deadline was missed, terminating her lease with CWRI-yet gas continued to be produced and proceeds split under the pooling agreement, and Sheppard sought her proportional share.

Whether the termination of a lease automatically terminates a pooling agreement that was entered into pursuant to the lease.