West Sussex Energy Partners · OGM-031 · Wyoming edition
Editorial update: October 16, 2026. General educational information.
Wyoming mineral-law cases require analysis of the actual holdings, instruments and procedural posture, not citations alone. In particular, McGee v. Caballo Coal Co. and Phoenix Capital Group Holdings, LLC v. Woods should be checked against the official opinions, their precise facts and subsequent treatment before a holding is applied to an ownership or royalty dispute.
Scope of Wyoming oil and gas case law
Report and index the holdings of Wyoming courts on mineral conveyances, lease interpretation, royalty payment, life estates, operations and fiduciary rights. Do not treat the facts or dicta of one dispute as a universal rule.
Research process
Start with official Wyoming Supreme Court opinions and the appellate case records. The official website notes that opinions prior to 2006 are not included in its current opinion search. Locate the court’s complete decision, validate reporter citations and subsequent treatment, and preserve the operative language of any deed or lease.
McGee v. Caballo Coal Company
McGee v. Caballo Coal Co., 2003 WY 68, 69 P.3d 908 (May 29, 2003), addressed specific 1973 deeds and agreements conveying coal-related interests while reserving oil and gas. The court held that those instruments did not convey coalbed methane, reversed summary judgment for the coal-company successor, and concluded the mineral owners were entitled to summary judgment. See ¶¶ 10–13, 19 and 22–26. The result depends on the instruments and circumstances; the opinion does not establish that every coal conveyance excludes coalbed methane. The official opinion is linked below; subsequent treatment and application to a different deed remain subject to legal review.
Phoenix Capital Group Holdings, LLC v. Woods
Phoenix Capital Group Holdings, LLC v. Woods, 2024 WY 104, 556 P.3d 1148 (October 4, 2024), affirmed orders granting dismissal and summary judgment. Under the deed at issue, the life tenant had no right to receive the royalty principal. The court also recognized the open-mines and express-deed-language exceptions to the general waste rule; see ¶¶ 11–16. It held the deed-reformation claim untimely because the ten-year period ran from the 2006 deed recording; see ¶¶ 20–25. Compare the actual deed, production history, agreements and claim before applying these holdings to another life estate. Subsequent treatment remains subject to legal review.
Agency orders and property rights
A drilling or pooling order can control regulated operations, but it does not necessarily adjudicate private mineral title. Record separately the deed chain, applicable regulatory order, agency jurisdiction and claims to revenue.
Suggested case index
Record case ID, formal citation, court, docket, decision date, question, holding, material facts, deed or lease language, paragraph pinpoints, subsequent history, official source URL, topics affected and last legal-review date.
Primary and supporting links
Wyoming Supreme Court Opinions; Wyoming appellate records; McGee official opinion (2003 PDF); Phoenix Capital official opinion (2024 PDF).
Wyoming Supreme Court: Union Pacific Resources Co. v. Texaco, Inc.
Union Pacific Resources Co. v. Texaco, Inc., 1994 WY 92, 882 P.2d 212 (Sept. 30, 1994; rehearing denied Nov. 2, 1994), involved the 1981 operating agreement of parties with natural-gas working interests in the Bruff Field, Moxa Arch area. WOGCC spacing initially covered 760 acres in the Frontier Formation and 640 acres in the deeper Dakota Formation. A 1990 WOGCC order enlarged the Dakota unit to 760 acres to protect correlative rights after BLM raised concerns over drainage of adjacent federal minerals. A separate compulsory pooling order followed in 1991.
Principal holdings for mineral owners: (1) regulatory spacing and compulsory pooling perform distinct functions; enlarging the spacing unit did not automatically apportion production (¶ 61); (2) the operating agreement was construed as accommodating agency orders and the court found no effective voluntary pooling of all Dakota interests in the enlarged area (¶¶ 46, 69–71); (3) the Court did not decide the separate pending challenge to the 1991 pooling order’s validity (¶ 71). Its judgment affirmed the contractual decision in the consolidated appeal.
Underlying record references: original 1981 WOGCC dockets 190-81 (Dakota) and 191-81 (Frontier), and later docket 404-90, as described in the published opinion. The signed orders have not been independently retrieved for this guide. The opinion is linked from a secondary reproduction because an official court-hosted copy of the pre-2006 opinion was not located; verify citation history and original documents before treating this chapter as publication-ready.
Linked guides: OGM-012 — Spacing and Pooling; OGM-030 — Federal Mineral Agreements.
Source-linked illustration: two different Dakota working-interest schedules
The reported decision reproduces both the 1981 operating-agreement working-interest fractions for the Dakota Formation (¶11) and the percentages in the June 13, 1991 WOGCC compulsory-pooling order as described to the Supreme Court (¶20). This is a reconstruction from the published appellate record, not an image of a signed agency order or a current division order.
| Party | 1981 Dakota contract | 1991 reported pooling order |
|---|---|---|
| Amoco | 46.71052% | 45.4379% |
| Union Pacific | 21.87500% | 24.4246% |
| Wexpro | 15.62501% | 17.1950% |
| Texaco | 15.78947% | 12.9425% |
Formation-specific CA: The opinion also describes an October 7, 1981 communitization agreement limited to the Frontier Formation (¶¶9, 66, 69). It did not provide voluntary pooling for the enlarged Dakota unit. The validity of the 1991 WOGCC compulsory-pooling order was left to separate litigation (¶71). The actual original agreement, 1991 order and subsequent procedural history must still be obtained before the registry treats them as authenticated agency source documents.
Sources and record custodians: Published case reproduction; WOGCC Records Contacts; BLM Wyoming Public Room.
Sources and scope
This guide provides general education. Subsequent case history and application to particular instruments require independent verification. Read the complete official opinion and later authorities before relying on a decision; a source being accessible does not establish its current precedential support. No professional engagement is created by browsing or an inquiry.
Case-law verification notice: McGee v. Caballo Coal Co., Phoenix Capital Group Holdings, LLC v. Woods, and older Wyoming authorities must be checked against official opinions for exact holdings, procedural posture, subsequent history and applicability to the mineral instrument at issue. Secondary reproductions alone are insufficient to certify current precedential treatment.
