Great Northern Properties v. Extraction Oil and Gas
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The case revolves around the ownership of mineral rights beneath a dedicated street in Greeley, Colorado. The dispute arose between Great Northern Properties, LLLP (GNP) and Extraction Oil and Gas, Inc., Richmark Energy Partners, LLC, and Richmark Royalties, LLC (collectively, Extraction) over who is entitled to receive certain oil and gas royalty payments. The issue at hand was how to determine who holds title to the mineral estate under a dedicated right-of-way when a grantor, who has an interest in the mineral rights under that right-of-way, executes a conveyance of the land abutting the right-of-way that is silent as to those rights.
The district court agreed with Extraction, concluding that the centerline presumption could be applied to a conveyance of the mineral estate beneath a right-of-way. The court of appeals affirmed the district court’s determination of law. However, the court of appeals also concluded that the centerline presumption should not apply if the grantor retains ownership of any property abutting the right-of-way.
The Supreme Court of the State of Colorado affirmed the court of appeals' decision that a conveyance of land abutting a right-of-way is presumed to carry title to the centerline of both the surface and mineral estates beneath a dedicated right-of-way to the owners of land abutting that right-of-way. However, the Supreme Court reversed the court of appeals' conclusion that the centerline presumption cannot apply if a grantor retains ownership of any property abutting the subject right-of-way. The Supreme Court held that the centerline presumption applies if the party claiming ownership to land abutting a dedicated right-of-way establishes that the grantor conveyed ownership of land abutting a right-of-way, the grantor owned the fee to both the surface estate and the mineral rights underlying the right-of-way at the time of conveyance, and no contrary intent appears on the face of the conveyance document.
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