Texas Outfitters Limited, Llc v. Carolyn Grace Nicholson, William Luther Carter, Jr., and Dora Jo Carter, Individually and as General Partner of Carter Ranch, Ltd.

Debra H. Lehrmann, Justice The holder of the executive right to lease a mineral estate owes non-participating mineral- and royalty-interest owners a duty of utmost good faith and fair dealing. We recently examined the scope of this duty and concluded that, while its parameters "are imprecise, at bottom, the executive is prohibited from engaging in acts of self-dealing that unfairly diminish the value of the non-executive interest." KCM Fin. LLC v. Bradshaw , 457 S.W.3d 70 , 74 (Tex. 2015). In this case, we are asked to apply the duty in the context of an executive's refusal to lease in…