Federal Court Rejects Takings Challenge to Ohio's Statutory Unitization Law In Kerns v. Chesapeake Exploration, LLC, No. 5:18-cv-00389, 2018 WL 2952662 (N.D. Ohio June 13, 2018), appeal docketed, No. 18-3636 (6th Cir. July 9, 2018), the U.S. District Court for the Northern District of Ohio dismissed a complaint filed by a group of landowners against Chesapeake Exploration, LLC (Chesapeake) and the Chief of the Ohio Department of Natural Resources, Division of Oil and Gas Resources Management, Richard J. Simmers, by indicating that the Ohio forced unitization statute, Ohio Rev. Code Ann. § 1509.28, does not violate the Fifth Amendment or the Fourteenth Amendment of the U.S. Constitution.
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