Legal Opinion

Harrison-Wyatt, LLC v. Ratliff

Supreme Court of Virginia

Decided March 5, 2004No. Record 030634PublishedCited by 10 opinions

1Opinion of the Court

SENIOR JUSTICE STEPHENSON

delivered the opinion of the Court.

This appeal presents a significant question of first impression in Virginia, to-wit: Where a surface owner of a tract of land, or his predecessor-in-title, has conveyed all the coal in and under his land, has title to the coal bed methane (CBM) passed to the coal owner along with the coal?

I

Harrison-Wyatt, LLC (the Coal Owner), is the successor grantee under three coal severance deeds from the 19th century. Donald Ratliff and others (the Plaintiffs) own the surface land and all minerals upon and within it, except the coal. The…

2Cases cited6 opinions

  1. Carbon County v. Union Reserve Coal Co., Inc.Montana Supreme Court · 1995
  2. Amoco Production Co. v. Southern Ute Indian TribeSupreme Court of the United States · 1999
  3. United States Steel Corp. v. HogeSupreme Court of Pennsylvania · 1983
  4. Energy Development Corp. v. MossWest Virginia Supreme Court · 2004
  5. Newman v. RAG Wyoming Land Co.Wyoming Supreme Court · 2002

1 more not listed; retrieve them via the Exa API.

3Cited by10 opinions

  1. EQT Production Company v. Robert AdairCourt of Appeals for the Fourth Circuit · 2014
  2. Central Natural Resources, Inc. v. Davis Operating Co.Supreme Court of Kansas · 2009
  3. Continental Resources of Illinois, Inc. v. Illinois Methane, LLCAppellate Court of Illinois · 2006
  4. Adair v. EQT Production Co.District Court, W.D. Virginia · 2017
  5. Cimarron Oil Corp. v. Howard Energy Corp.Indiana Court of Appeals · 2009

5 more not listed; retrieve them via the Exa API.

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