Anadarko Petroleum Corp. v. State Oil & Gas Board of Mississippi, 99 So. 3d 109

In 1980, the Board force-integrated all interests in a 640-acre Rhoda Lee Brown No. 1 Well unit in Hancock County.
Kelly Oil obtained the leases and became operator by 1992.
In 2005–2006, Anadarko acquired about one-third of the Rhoda Brown Well drilling rights after Kelly Oil let some leases expire.
Kelly Oil charged Anadarko its share of more than $1.5 million in well costs; Anadarko disputed over $900,000 and petitioned the Board under Mississippi Code § 53-3-7(4) to determine propriety.
The Board proposed an order in March 2010 that all costs were actual, reasonable, and necessary but lacked findings of fact and reasoning; Anadarko requested proper findings.
After revisions, the Board issued a final order on April 12, 2010; the chancery court affirmed, and Anadarko appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Are the Board's findings sufficient for review?	Anadarko: lack of detailed findings; insufficient basis for review.	Kelly Oil/Board: record supports the costs despite fewer explicit findings.	Vacate and remand for proper factual findings.

Pursue Energy Corp. v. State Oil & Gas Bd., 524 So.2d 569 (Miss. 1988) (operators may recover only actual, reasonable, necessary costs)
McGowan v. Miss. State Oil & Gas Bd., 604 So.2d 312 (Miss. 1992) (requirement of sufficient reasoning for meaningful review)
Sierra Club, Inc. v. Miss. Dep’t of Envtl. Quality, 819 So.2d 515 (Miss. 2002) (lack of reasoned decision undermines review)
Limbert v. Miss. Univ. for Women Alumnae Ass’n, Inc., 998 So.2d 993 (Miss. 2008) (separation of powers restricts court from substituting judgment)
Davis v. Pub. Employees’ Ret. Sys., 750 So.2d 1225 (Miss. 1999) (separation of powers limits judicial review of agency action)