Absolute Oil + Gas, LLC v. Chord Energy Corporation F/K/A Oasis Petroleum, Inc. Oasis Petroleum North America, LLC; Oasis Midstream Services, LLC; Crestwood Midstream Partners, LP; Oasis Midstream Partners LP; Crestwood Equity Partners LP; OMP GP, LLP; Michael Lou; Taylor Reid; Thomas Nusz; And Nickolas Lorentzatos

Plain English (For Everyone)

Imagine you sign a contract to sell your house, but it only lets you sell the house you own *today*. This court case is like that for oil and gas rights. The contract said future oil rights couldn't be sold, and the court agreed, meaning the buyer didn't get the rights they thought they bought. It's all about what the contract clearly says about what can and can't be sold.

For Legal Practitioners

This decision reinforces the principle that unambiguous contract language, particularly concerning the assignment of future interests, will be strictly construed. The court's focus on the 'plain language' of the assignment clause, absent any explicit authorization for future interests, serves as a critical reminder for practitioners to meticulously draft and review such provisions. Future litigation strategies should emphasize the precise wording of assignment clauses to avoid disputes over the scope of transferred rights.

For Law Students

This case tests the doctrine of contract interpretation, specifically regarding the assignment of future interests in oil and gas leases. The court applied the plain meaning rule, holding that an assignment clause must explicitly permit the transfer of future interests for it to be valid. This aligns with general contract law principles that future property cannot be assigned unless specifically contemplated and agreed upon, raising exam issues about the enforceability of broad assignment clauses.

Newsroom Summary

A Texas appeals court ruled that future oil and gas rights cannot be sold unless a contract explicitly states so. This decision impacts energy companies and investors by clarifying that only currently owned interests are transferable under standard assignment clauses, potentially affecting the valuation and trading of oil and gas assets.

Constitutional Issues

Contract interpretationSufficiency of pleadings

Rule Statements

"A party seeking to recover damages for breach of contract must allege facts that, if proven, would show the existence of a valid contract, the plaintiff's performance or tender of performance, the defendant's breach, and damages resulting from the breach."

"In reviewing a trial court's order granting a motion to dismiss for failure to state a claim, we must construe the pleadings in the light most favorable to the non-movant and determine if the pleadings, viewed in the light most favorable to the non-movant, allege facts that state a plausible claim for relief."

Scenario: You sign a contract to sell your car, but the contract only mentions selling the car you currently own. Later, you inherit another car and try to sell that one under the same contract, but the seller says it's not included.

Your Rights: You have the right to only sell what you currently own, unless the contract specifically states it covers future acquisitions or inheritances.

What To Do: Carefully review any contract that involves selling or transferring property, especially if it could involve items you might acquire in the future. If you intend to transfer future property, ensure the contract explicitly includes language to that effect.

Is it legal to assign future rights or property I might acquire later?

It depends. Generally, you can only assign rights or property that you currently own or are entitled to. However, if a contract specifically and clearly states that future rights or property are included in the assignment, it may be legal. This ruling emphasizes that such intent must be explicit in the agreement.

This ruling is from a Texas appellate court and interprets Texas law regarding contracts. While the principles of contract interpretation are broadly similar across jurisdictions, specific outcomes can vary based on local statutes and case law.

For Oil and Gas Companies

Companies relying on broad assignment clauses to acquire future interests may face challenges. This ruling necessitates a review of existing agreements and a more precise drafting of future contracts to clearly define the scope of assigned rights.

For Investors in Energy Sector

Investors need to be aware that the acquisition of future oil and gas interests is not guaranteed under standard assignment clauses. Due diligence on contracts will be even more critical to understand precisely which assets are being transferred.

Q: What is Absolute Oil + Gas, LLC v. Chord Energy Corporation F/K/A Oasis Petroleum, Inc. Oasis Petroleum North America, LLC; Oasis Midstream Services, LLC; Crestwood Midstream Partners, LP; Oasis Midstream Partners LP; Crestwood Equity Partners LP; OMP GP, LLP; Michael Lou; Taylor Reid; Thomas Nusz; And Nickolas Lorentzatos about?

Absolute Oil + Gas, LLC v. Chord Energy Corporation F/K/A Oasis Petroleum, Inc. Oasis Petroleum North America, LLC; Oasis Midstream Services, LLC; Crestwood Midstream Partners, LP; Oasis Midstream Partners LP; Crestwood Equity Partners LP; OMP GP, LLP; Michael Lou; Taylor Reid; Thomas Nusz; And Nickolas Lorentzatos is a case decided by Texas Court of Appeals on March 19, 2026. It involves Contract.

Q: What court decided Absolute Oil + Gas, LLC v. Chord Energy Corporation F/K/A Oasis Petroleum, Inc. Oasis Petroleum North America, LLC; Oasis Midstream Services, LLC; Crestwood Midstream Partners, LP; Oasis Midstream Partners LP; Crestwood Equity Partners LP; OMP GP, LLP; Michael Lou; Taylor Reid; Thomas Nusz; And Nickolas Lorentzatos?

Absolute Oil + Gas, LLC v. Chord Energy Corporation F/K/A Oasis Petroleum, Inc. Oasis Petroleum North America, LLC; Oasis Midstream Services, LLC; Crestwood Midstream Partners, LP; Oasis Midstream Partners LP; Crestwood Equity Partners LP; OMP GP, LLP; Michael Lou; Taylor Reid; Thomas Nusz; And Nickolas Lorentzatos was decided by the Texas Court of Appeals, which is part of the TX state court system. This is a state appellate court.

Q: When was Absolute Oil + Gas, LLC v. Chord Energy Corporation F/K/A Oasis Petroleum, Inc. Oasis Petroleum North America, LLC; Oasis Midstream Services, LLC; Crestwood Midstream Partners, LP; Oasis Midstream Partners LP; Crestwood Equity Partners LP; OMP GP, LLP; Michael Lou; Taylor Reid; Thomas Nusz; And Nickolas Lorentzatos decided?

Absolute Oil + Gas, LLC v. Chord Energy Corporation F/K/A Oasis Petroleum, Inc. Oasis Petroleum North America, LLC; Oasis Midstream Services, LLC; Crestwood Midstream Partners, LP; Oasis Midstream Partners LP; Crestwood Equity Partners LP; OMP GP, LLP; Michael Lou; Taylor Reid; Thomas Nusz; And Nickolas Lorentzatos was decided on March 19, 2026.

Q: What is the citation for Absolute Oil + Gas, LLC v. Chord Energy Corporation F/K/A Oasis Petroleum, Inc. Oasis Petroleum North America, LLC; Oasis Midstream Services, LLC; Crestwood Midstream Partners, LP; Oasis Midstream Partners LP; Crestwood Equity Partners LP; OMP GP, LLP; Michael Lou; Taylor Reid; Thomas Nusz; And Nickolas Lorentzatos?

The citation for Absolute Oil + Gas, LLC v. Chord Energy Corporation F/K/A Oasis Petroleum, Inc. Oasis Petroleum North America, LLC; Oasis Midstream Services, LLC; Crestwood Midstream Partners, LP; Oasis Midstream Partners LP; Crestwood Equity Partners LP; OMP GP, LLP; Michael Lou; Taylor Reid; Thomas Nusz; And Nickolas Lorentzatos is . Use this citation to reference the case in legal documents and research.

Q: What type of case is Absolute Oil + Gas, LLC v. Chord Energy Corporation F/K/A Oasis Petroleum, Inc. Oasis Petroleum North America, LLC; Oasis Midstream Services, LLC; Crestwood Midstream Partners, LP; Oasis Midstream Partners LP; Crestwood Equity Partners LP; OMP GP, LLP; Michael Lou; Taylor Reid; Thomas Nusz; And Nickolas Lorentzatos?

Absolute Oil + Gas, LLC v. Chord Energy Corporation F/K/A Oasis Petroleum, Inc. Oasis Petroleum North America, LLC; Oasis Midstream Services, LLC; Crestwood Midstream Partners, LP; Oasis Midstream Partners LP; Crestwood Equity Partners LP; OMP GP, LLP; Michael Lou; Taylor Reid; Thomas Nusz; And Nickolas Lorentzatos is classified as a "Contract" case. This describes the nature of the legal dispute at issue.

Q: What is the case name and what was the main issue in Absolute Oil + Gas, LLC v. Chord Energy Corporation?

The case is Absolute Oil + Gas, LLC v. Chord Energy Corporation, et al. The central dispute revolved around the interpretation of an 'assignment' clause within an oil and gas operating agreement. Specifically, the court had to determine whether this clause permitted the assignment of future oil and gas interests.

Q: Who were the main parties involved in the Absolute Oil + Gas v. Chord Energy lawsuit?

The primary parties were Absolute Oil + Gas, LLC, the plaintiff seeking to acquire certain oil and gas interests, and Chord Energy Corporation (formerly Oasis Petroleum, Inc.), along with its related entities like Oasis Petroleum North America, LLC, Oasis Midstream Services, LLC, and others, who were the defendants and assignors of the interests.

Q: Which court decided the Absolute Oil + Gas v. Chord Energy case, and what was its ruling?

The case was decided by the Texas Court of Appeals (texapp). The appellate court affirmed the trial court's decision, ruling that the assignment clause in the operating agreement did not allow for the assignment of future oil and gas interests.

Q: When was the decision in Absolute Oil + Gas, LLC v. Chord Energy Corporation issued?

The provided summary does not specify the exact date of the appellate court's decision, but it indicates that the appellate court affirmed the trial court's ruling on the interpretation of the assignment clause.

Q: What type of agreement was at the heart of the dispute in Absolute Oil + Gas v. Chord Energy?

The core of the dispute was an oil and gas operating agreement. The specific provision under scrutiny was the 'assignment' clause within this agreement, which dictated the terms under which parties could transfer their rights and interests.

Q: Is Absolute Oil + Gas, LLC v. Chord Energy Corporation F/K/A Oasis Petroleum, Inc. Oasis Petroleum North America, LLC; Oasis Midstream Services, LLC; Crestwood Midstream Partners, LP; Oasis Midstream Partners LP; Crestwood Equity Partners LP; OMP GP, LLP; Michael Lou; Taylor Reid; Thomas Nusz; And Nickolas Lorentzatos published?

Absolute Oil + Gas, LLC v. Chord Energy Corporation F/K/A Oasis Petroleum, Inc. Oasis Petroleum North America, LLC; Oasis Midstream Services, LLC; Crestwood Midstream Partners, LP; Oasis Midstream Partners LP; Crestwood Equity Partners LP; OMP GP, LLP; Michael Lou; Taylor Reid; Thomas Nusz; And Nickolas Lorentzatos is a published, precedential opinion. Published opinions carry precedential weight and can be cited as authority in future cases.

Q: What was the ruling in Absolute Oil + Gas, LLC v. Chord Energy Corporation F/K/A Oasis Petroleum, Inc. Oasis Petroleum North America, LLC; Oasis Midstream Services, LLC; Crestwood Midstream Partners, LP; Oasis Midstream Partners LP; Crestwood Equity Partners LP; OMP GP, LLP; Michael Lou; Taylor Reid; Thomas Nusz; And Nickolas Lorentzatos?

The court ruled in favor of the defendant in Absolute Oil + Gas, LLC v. Chord Energy Corporation F/K/A Oasis Petroleum, Inc. Oasis Petroleum North America, LLC; Oasis Midstream Services, LLC; Crestwood Midstream Partners, LP; Oasis Midstream Partners LP; Crestwood Equity Partners LP; OMP GP, LLP; Michael Lou; Taylor Reid; Thomas Nusz; And Nickolas Lorentzatos. Key holdings: The court held that the "assignment" clause in the operating agreement did not grant the right to assign future interests because the language used, such as "all of its rights, title, and interest in and to the Leases and the Hydrocarbons in place," referred to existing, present interests, not those that might come into existence later.; The court affirmed the trial court's summary judgment, finding that the plaintiff failed to demonstrate it acquired the disputed interests through the assignment, as the assignment only covered existing interests and the disputed interests were future interests.; The court applied the principle of contract interpretation that unambiguous contract language must be given its plain meaning, and that the intent of the parties is derived from the written instrument itself.; The court rejected the plaintiff's argument that the assignment should be interpreted broadly to include future interests, stating that such an interpretation would require adding language to the contract that was not present.; The court found that the "effective date" of the assignment further supported the interpretation that only existing interests were conveyed, as it indicated a transfer of rights as of that specific point in time..

Q: What precedent does Absolute Oil + Gas, LLC v. Chord Energy Corporation F/K/A Oasis Petroleum, Inc. Oasis Petroleum North America, LLC; Oasis Midstream Services, LLC; Crestwood Midstream Partners, LP; Oasis Midstream Partners LP; Crestwood Equity Partners LP; OMP GP, LLP; Michael Lou; Taylor Reid; Thomas Nusz; And Nickolas Lorentzatos set?

Absolute Oil + Gas, LLC v. Chord Energy Corporation F/K/A Oasis Petroleum, Inc. Oasis Petroleum North America, LLC; Oasis Midstream Services, LLC; Crestwood Midstream Partners, LP; Oasis Midstream Partners LP; Crestwood Equity Partners LP; OMP GP, LLP; Michael Lou; Taylor Reid; Thomas Nusz; And Nickolas Lorentzatos established the following key holdings: (1) The court held that the "assignment" clause in the operating agreement did not grant the right to assign future interests because the language used, such as "all of its rights, title, and interest in and to the Leases and the Hydrocarbons in place," referred to existing, present interests, not those that might come into existence later. (2) The court affirmed the trial court's summary judgment, finding that the plaintiff failed to demonstrate it acquired the disputed interests through the assignment, as the assignment only covered existing interests and the disputed interests were future interests. (3) The court applied the principle of contract interpretation that unambiguous contract language must be given its plain meaning, and that the intent of the parties is derived from the written instrument itself. (4) The court rejected the plaintiff's argument that the assignment should be interpreted broadly to include future interests, stating that such an interpretation would require adding language to the contract that was not present. (5) The court found that the "effective date" of the assignment further supported the interpretation that only existing interests were conveyed, as it indicated a transfer of rights as of that specific point in time.

Q: What are the key holdings in Absolute Oil + Gas, LLC v. Chord Energy Corporation F/K/A Oasis Petroleum, Inc. Oasis Petroleum North America, LLC; Oasis Midstream Services, LLC; Crestwood Midstream Partners, LP; Oasis Midstream Partners LP; Crestwood Equity Partners LP; OMP GP, LLP; Michael Lou; Taylor Reid; Thomas Nusz; And Nickolas Lorentzatos?

1. The court held that the "assignment" clause in the operating agreement did not grant the right to assign future interests because the language used, such as "all of its rights, title, and interest in and to the Leases and the Hydrocarbons in place," referred to existing, present interests, not those that might come into existence later. 2. The court affirmed the trial court's summary judgment, finding that the plaintiff failed to demonstrate it acquired the disputed interests through the assignment, as the assignment only covered existing interests and the disputed interests were future interests. 3. The court applied the principle of contract interpretation that unambiguous contract language must be given its plain meaning, and that the intent of the parties is derived from the written instrument itself. 4. The court rejected the plaintiff's argument that the assignment should be interpreted broadly to include future interests, stating that such an interpretation would require adding language to the contract that was not present. 5. The court found that the "effective date" of the assignment further supported the interpretation that only existing interests were conveyed, as it indicated a transfer of rights as of that specific point in time.

Q: What is the legal significance of the 'assignment' clause in an oil and gas operating agreement, as discussed in this case?

The 'assignment' clause in an oil and gas operating agreement defines the conditions and scope under which a party can transfer its rights and obligations to another party. In this case, the key question was whether the clause, as written, encompassed the transfer of interests that had not yet come into existence or been acquired by the assignor.

Q: What was the appellate court's holding regarding the assignment of future interests in Absolute Oil + Gas v. Chord Energy?

The appellate court held that the assignment clause in the operating agreement, as interpreted by the court, did not permit the assignment of future oil and gas interests. Consequently, Absolute Oil + Gas, LLC did not acquire the disputed interests through the assignment.

Q: On what basis did the court in Absolute Oil + Gas v. Chord Energy interpret the assignment clause?

The court's reasoning focused on the plain language of the assignment clause within the operating agreement. It applied established legal principles of contract interpretation to ascertain the intent of the parties as expressed in the written terms of the contract.

Q: Did the court consider any specific statutes or prior case law in its interpretation of the assignment clause?

While the summary emphasizes the plain language and general contract interpretation principles, it implies that established legal principles regarding contract interpretation were applied. These principles often draw upon statutory frameworks and prior judicial decisions (precedent) concerning contract law.

Q: What legal standard did the court likely apply when reviewing the trial court's interpretation of the contract?

When reviewing a trial court's interpretation of a contract, an appellate court typically applies a de novo standard of review. This means the appellate court examines the contract and makes its own independent determination of the contract's meaning without giving deference to the trial court's legal conclusions.

Q: What does it mean for an assignment to cover 'future interests' in the context of oil and gas law?

An assignment of 'future interests' in oil and gas law would typically refer to the transfer of rights to hydrocarbons or leasehold interests that the assignor does not yet own or possess at the time of the assignment, but expects to acquire later. This contrasts with assigning currently owned and existing interests.

Q: How does the plain language rule of contract interpretation apply to this case?

The plain language rule dictates that the meaning of a contract should be determined from the words used in the document itself, assuming those words have a clear and ordinary meaning. The court in this case relied on this rule to conclude that the assignment clause did not extend to future interests because the language did not explicitly or implicitly permit it.

Q: What is the burden of proof in a contract dispute like Absolute Oil + Gas v. Chord Energy?

In a contract dispute where one party claims rights under an assignment, the burden of proof generally lies with the party asserting the claim. Absolute Oil + Gas, LLC would have had the burden to prove that the assignment agreement, as written, legally transferred the disputed future interests to them.

Q: What are the potential real-world implications of this ruling for oil and gas transactions?

This ruling highlights the critical importance of precise language in oil and gas agreements. It suggests that parties seeking to assign or acquire future interests must clearly and unambiguously state this intent in the contract, otherwise, such assignments may be deemed invalid, impacting deal certainty and future resource development.

Q: Who is most affected by the outcome of Absolute Oil + Gas v. Chord Energy?

Oil and gas companies, mineral owners, and investors involved in acquiring or assigning leasehold rights are most directly affected. The decision impacts how they draft and interpret assignment clauses, potentially affecting the valuation and transferability of both current and future oil and gas assets.

Q: What changes, if any, should companies make to their standard operating agreements after this decision?

Companies should review and potentially revise their standard assignment clauses to explicitly address whether future interests are included or excluded. Clearer language is needed to avoid ambiguity and potential litigation, ensuring that assignments accurately reflect the parties' intentions regarding the transfer of both present and future rights.

Q: Does this ruling affect existing oil and gas leases or only future assignments?

The ruling specifically interprets an assignment clause within an existing operating agreement concerning the transfer of interests. It doesn't directly invalidate existing leases but clarifies how assignments of interests derived from those leases, particularly future ones, must be clearly defined to be enforceable.

Q: What compliance considerations arise from this case for businesses in the energy sector?

Businesses in the energy sector must ensure their contractual language regarding assignments is precise and legally sound. Compliance involves meticulous drafting of assignment clauses to clearly define the scope of transferred interests, thereby avoiding disputes and ensuring that transactions align with regulatory and legal expectations.

Q: How does this case fit into the broader history of oil and gas contract interpretation?

This case continues a long tradition in oil and gas law where disputes frequently arise from the interpretation of complex contractual language, particularly concerning the conveyance of property rights. It reinforces the principle that clear and specific language is paramount in defining the scope of rights transferred, especially when dealing with the unique nature of oil and gas interests.

Q: Are there landmark cases that established principles of contract interpretation relevant to this dispute?

Yes, numerous landmark cases in contract law and oil and gas law have established principles for interpreting ambiguous or disputed contract terms. These cases often emphasize the importance of the 'four corners' of the document, the plain meaning of words, and the intent of the parties as expressed within the agreement.

Q: How has the doctrine of assignment evolved in oil and gas law, and where does this case fit?

The doctrine of assignment in oil and gas law has evolved to address the complexities of transferring rights in a resource that is often developed over time. This case fits by applying established contract principles to a specific scenario involving future interests, underscoring the need for explicit contractual provisions to govern such transfers.

Q: What was the docket number in Absolute Oil + Gas, LLC v. Chord Energy Corporation F/K/A Oasis Petroleum, Inc. Oasis Petroleum North America, LLC; Oasis Midstream Services, LLC; Crestwood Midstream Partners, LP; Oasis Midstream Partners LP; Crestwood Equity Partners LP; OMP GP, LLP; Michael Lou; Taylor Reid; Thomas Nusz; And Nickolas Lorentzatos?

The docket number for Absolute Oil + Gas, LLC v. Chord Energy Corporation F/K/A Oasis Petroleum, Inc. Oasis Petroleum North America, LLC; Oasis Midstream Services, LLC; Crestwood Midstream Partners, LP; Oasis Midstream Partners LP; Crestwood Equity Partners LP; OMP GP, LLP; Michael Lou; Taylor Reid; Thomas Nusz; And Nickolas Lorentzatos is 01-24-00180-CV. This identifier is used to track the case through the court system.

Q: Can Absolute Oil + Gas, LLC v. Chord Energy Corporation F/K/A Oasis Petroleum, Inc. Oasis Petroleum North America, LLC; Oasis Midstream Services, LLC; Crestwood Midstream Partners, LP; Oasis Midstream Partners LP; Crestwood Equity Partners LP; OMP GP, LLP; Michael Lou; Taylor Reid; Thomas Nusz; And Nickolas Lorentzatos be appealed?

Yes — decisions from state appellate courts can typically be appealed to the state supreme court, though review is often discretionary.

Q: How did the case reach the Texas Court of Appeals?

The case reached the Texas Court of Appeals after a trial court rendered a decision. Typically, a party dissatisfied with the trial court's judgment files an appeal, asking the appellate court to review the trial court's rulings for errors of law or fact.

Q: What procedural issue was central to the appellate court's review?

The central procedural issue was the appellate court's review of the trial court's interpretation of the assignment clause. The appellate court likely reviewed whether the trial court correctly applied the law in determining that the clause did not permit the assignment of future interests.

Q: Did the appellate court consider any evidentiary issues in its decision?

The provided summary focuses on the legal interpretation of the contract language. While evidentiary issues can arise in contract disputes, this summary does not indicate that they were a primary focus of the appellate court's decision in affirming the trial court's ruling on the contract's meaning.

Q: What is the significance of the appellate court affirming the trial court's decision?

Affirming the trial court's decision means the appellate court found no reversible error in the trial court's judgment. In this instance, it validates the trial court's interpretation that the assignment clause did not allow for the transfer of future oil and gas interests, making that interpretation the binding legal conclusion.