Conocophillips Company, Rodolfo C. Ramirez, Individually and as Independent Administrator of the Estate of Ileana Ramirez, and El Milagro Minerals, Ltd. v. Leon Oscar Ramirez, Jr., Individually, and Jesus M. Dominguez, as Guardian of the Estate of Minerva Clementina Ramirez, an Incapacitated Person, 599 S.W.3d 296

Background:

The Ramirez family owned 7,016 acres in Zapata County; in 1941 the surface was partitioned among heirs while the mineral estate was severed and kept undivided across the larger tract.
Over decades the surface parcels were further partitioned; a 1,058-acre parcel was identified as "Las Piedras Ranch/Las Piedras Pasture" and conveyed as a surface parcel only, with express exclusions for oil, gas, and other minerals.
Leonor (a co-owner) acquired a 1/2 undivided surface interest in Las Piedras and a 1/4 undivided mineral interest in the full 7,016 acres; she executed a 1987 will devising a life estate in "all of [her] right, title and interest in and to Ranch 'Las Piedras'" to her son Leon Oscar Sr., with the remainder to his children, and devised the residuary equally among her three children.
Family members consistently treated the minerals as undivided across the whole 7,016 acres and leased minerals in accordance with that shared ownership; the parties at the time understood Leonor’s residuary to include her mineral interest.
After Leon Oscar Sr. died, his children sued, claiming the life estate in Las Piedras included the minerals under Las Piedras (so the minerals did not pass in residuary), and sought damages and an accounting from lessees; the trial court and court of appeals ruled for the respondents and awarded damages against ConocoPhillips.
The Texas Supreme Court granted review and reversed: it held the phrase "Ranch 'Las Piedras'" in Leonor’s will referred only to the surface estate as the family understood the term when the will was executed, so the mineral interest remained in the residuary.

Issues:

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the devise of "all... right, title and interest in and to Ranch 'Las Piedras'" included the mineral estate beneath Las Piedras	The devise conveyed both surface and minerals to the life tenant; remainder did not include those minerals	The phrase referred only to the surface as the family documents and transactions showed; minerals remained in the residuary	The phrase conveyed only the surface estate; minerals remained part of Leonor’s residuary and passed equally to her three children
Whether extrinsic evidence of family transactions may resolve the term's meaning	Ambiguity should be resolved for respondents' construction	Courts may consider circumstances at will execution to determine the term’s specific family meaning	Court considered surrounding conveyances and held they showed "Las Piedras" meant surface only

Key Cases Cited

San Antonio Area Found. v. Lang, 35 S.W.3d 636 (Tex. 2000) (will construction focuses on testator intent from will text)
Shriner’s Hosp. for Crippled Children of Tex. v. Stahl, 610 S.W.2d 147 (Tex. 1980) (court should ascertain intent from the four corners of the will when possible)
Huffman v. Huffman, 339 S.W.2d 885 (Tex. 1960) (general principles of testamentary construction emphasizing intent)
Henderson v. Parker, 728 S.W.2d 768 (Tex. 1987) (intent is determined as of the time the will was executed)
Hysaw v. Dawkins, 483 S.W.3d 1 (Tex. 2016) (when a will term is ambiguous, courts may consider surrounding circumstances to interpret it)