Oil and Gas Leases: Assignment

摘要

In 1993, First Community Church executes an oil and gas lease with Solid Rock which requires the Church to pre-approve all proposed drill sites because the acreage involved is used as a campground. In 1997, Solid Rock enters into a verbal agreement with OEA where OEA would drill several wells and if successful would receive an assignment of the lease. OEA and Solid Rock then agree to drill several additional wells but the Church does not allow seven of the proposed sites to be drilled. In 2002, OEA brings this action against Solid Rock and the Church for breach of the lease and for not properly assigning a working interest as per the 1997 agreement. The Church argues that OEA lacks standing to claim a breach of the lease since they are neither a party nor a successor in interest. OEA argues that it received an assignment of the lease from Solid Rock. The trial court grants the defendants' motion for summary judgment rejecting the claim that an assignment had ever been executed. Held: affirmed.