Samson Lone Star, Ltd. Partnership v. Hooks, 389 S.W.3d 409

Samson Lone Star drilled wells within buffer zones of Hooks' Jefferson County Lease and Hardin County Leases, triggering Article VI(A) offset obligations.
Samson pursued pooling and unit designations (BSM No. 1, BSM A-l, DuJay No. 1, DuJay A-l) involving Hooks’ leases and other parties, sometimes without full consent.
Plaintiff Hooks alleged fraud, fraudulent inducement, statutory fraud, formation production royalty issues, unpooling damages, and most-favored-nations damages stemming from pooling actions and misrepresentations.
Trial court granted partial summary judgments on several pooling-related claims; the jury later found fraud and statutory fraud regarding the BSM No. 1 unit and awarded damages.
On rehearing, the court reversed most of the trial judgment, held limitations bar the fraud claims, adjusted post-judgment interest to five percent, and vacated injunctive relief and certain fees.
Hooks cross-appealed seeking affirmative relief on offset obligations; the court held that Hooks’ cross-claims were time-barred and affirmed Samson’s summary judgments on those claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Fraud claims and statute of limitations	Hooks claim fraud discovery within limitations period.	Fraud claims accrued in February 2001; filed May 2007 beyond four-year limit.	Fraud claims barred by limitations
Validity and termination of the BSM A-l unit; unpooling	Hooks not bound by amended/unpooled units; BSM A-l valid and royalties owed.	Hooks ratified amended units by accepting royalties; unpooling claim barred.	Hooks estopped to assert interest in BSM A-l royalties; unpooling claim sustained against them cannot prevail
Most favored nations clause interpretation	State pooling royalty higher than Hooks triggers MFN clause.	State pooling royalty is not a true MFN trigger for Hooks; no higher Third Party Lease)	MFN clause not triggered by Samson-State pooling agreement
Formation production clause duplicative royalties	Formation production clause requires additional royalties for condensate liquid when produced.	Formation production does not double-pay condensate; contract language unambiguous.	Formation production clause does not double royalties; Hooks take nothing on that theory
Permanent injunction and related relief	Injunction necessary to enforce contract provisions.	Injunction unwarranted; lacks irreparable harm and remedy at law.	Permanent injunction vacated; improper as to contract enforcement

Dow Chem., Co. v. Francis, 46 S.W.3d 237 (Tex. 2001) (fraud elements; accrual and discovery rules)
Emerald Oil & Gas Co. v. Exxon Mobil Corp., 348 S.W.3d 194 (Tex. 2011) (fraud statute accrual; discovery rule applicability)
Little v. Smith, 943 S.W.2d 414 (Tex. 1997) (discovery rule for fraud accrual)
HECI Exploration Co. v. Neel, 982 S.W.2d 881 (Tex. 1998) (discovery rule and royalty claims in oil and gas)
Tittizer v. Union Gas Corp., 171 S.W.3d 857 (Tex. 2005) (pooling authority; contract interpretation; joinder)
Ladd Petroleum Corp. v. Eagle Oil & Gas Co., 695 S.W.2d 99 (Tex. App.-Fort Worth 1985) (joinder and pooling authority; unit validity)
Whelan v. Placid Oil Co., 274 S.W.2d 125 (Tex. Civ. App.-Texarkana 1954) (estoppel by acceptance of royalties; unit validity)
Fortune Prod. Co. v. Conoco, Inc., 52 S.W.3d 671 (Tex. 2000) (ratification doctrine in pooling)
Cambridge Prod. Inc. v. Geodyne Nominee Corp., 292 S.W.3d 725 (Tex. App.-Amarillo 2009) (estoppel and unitization; consent to pooling)
Williamson v. Mobil Producing Tex. & N.M., Inc., 737 S.W.2d 917 (Tex. App.-Beaumont 1987) (unit dissolution limitations; production-based continuing units)