Northern Oil and Gas, Inc. v. EOG Resources, Inc., No. 22-2053 (8th Cir. 2023)
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In June 1949, Axel Anderson conveyed to L.S. Youngblood a ½ mineral interest in several tracts of land in Mountrail County, North Dakota (“the Disputed Lands”)In 2011, with the Andersons and Henry Johnson now deceased, grantee Johnson’s successors filed a quiet title action in state court against Nancy Finkle and grantor Andersons’ other successors to resolve the over conveyance, seeking title to a ½ mineral interest in the Disputed Lands (“the Finkle Litigation”).inkle appealed the quiet title order and judgment, arguing that an exception to the Duhig rule that is not at issue in this appeal applied and therefore the trial court should have awarded each side a 1/4 mineral interest in the Disputed Lands. In January 2008, Finkle, a successor to grantor Andersons’ mineral interests, conveyed by oil and gas lease her mineral interest leasehold and operating rights in the Disputed Lands to Montana Oil Properties, Inc. Northern Oil did not participate while Finkle defended the Johnson successors’ quiet title claim and asserted her own deed reformation counterclaim in state court.
The Eighth Circuit affirmed, holding that the district court correctly granted summary judgment to the defendant on the ground that due to an over-conveyance of rights, Plaintiff had not obtained any mineral rights in the subject property when it acquired its interest in a leasehold. Further, the court held that the district court granted summary judgment dismissing Northern Oil’s reformation claim as time-barred by the ten-year statute of limitations in N.D.C.C. Section 28-01-15(2), applying a Supreme Court of North Dakota decision issued after the Finkle Litigation, Western Energy Corp. v. Stauffer, 921 N.W.2d 431, 434-35 (N.D. 2019).
Court Description: [Loken, Author, with Shepherd and Kelly, Circuit Judges] Civil case - Mineral rights. For the court's prior opinion in the matter see, N. Oil & Gas, Inc. v. EOG Res., Inc., 970 F.3d 889 (8th Cir. 2020). On remand, the district court correctly granted summary judgment to the defendant on the ground that due to an over-conveyance of rights, the plaintiff had not obtained any mineral rights in the subject property when it acquired its interest in a leasehold - see Johnson v. Finkle, 837 N.W. 2d 132 (N.D. 2013). [ July 14, 2023 ]
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