Mark Carpenter and Carpco Efficient Energy, L.L.C. v. Chris Phelps and Steve Helms

OPINION

JIM SHARP, Justice.

The issue posed here is whether documents that recite a description of real property as Texas Railroad Commission “Oil Lse/Gas ID no. 08294” and “the M.T. Cole ‘A’ Lease in Gregg County, Texas” are sufficient to satisfy the statute of frauds. 1 We hold that because the pertinent documents do not furnish within themselves, or by reference to other existing writings, the means or data by which the land may be identified with reasonable certainty, the statute of frauds is not satisfied, and we reverse. 2

Background

This dispute arises out of a business transaction between…