Westland Oil Development Corp. v. Gulf Oil Corp.
Supreme Court of Texas
637 S.W.2d 903 (Tex. 1982)
Mobil's farmout to Westland (plaintiff), later assigned to Chambers & Kennedy (C&K) with an area-of-mutual-interest letter agreement, led to an operating agreement between Mobil and C&K that expressly stated the earlier farmout and letter agreements would control in any conflict; Mobil later farmed out overlapping land to Hanson, whose agreement referenced the Mobil-C&K operating agreement, and Hanson assigned to Gulf (defendant), which drilled and received assignments from Mobil. Westland sued Gulf to enforce the letter agreement's mutual-interest provision, and Gulf claimed it lacked notice; the trial court granted Westland summary judgment, the court of appeals reversed, and Westland appealed.
Whether a purchaser is bound by every recital, reference, and reservation contained in or fairly disclosed by any instrument forming an essential link in the chain of title under which the purchaser claims.