RL Clark, L.L.C. v. Hammond

Citations

• 2024 Ohio 5051

Syllabus

1902 oil and gas reservation extinguished in a 1956 deed by marketable title act; Blackstone v. Moore, 2018-Ohio-4959; prior mineral interest reference was general, no specific identification of a prior recorded interest as part of the reference; mere mention of a prior recorded interest somewhere in a deed does not prevent extinguishment under Blackstone 3-part test; oil and gas lease can be a title transaction that acts as a savings event under the MTA, but the interest to be saved must arise out of the lease; mere filing of an oil and gas lease by the surface owner does not preserve a non-participating royalty interest under the MTA; judgment affirmed.