Oklahoma v. Texas

Background

T. P. Roberts and A. H. Britain claimed royalty rights from oil taken from three wells just south of Red River. The Durfee Mineral Company claimed the same land based on a later survey. The core dispute was whether an 1861 survey (the Powell survey) went all the way to the south bank of Red River or left a narrow wedge of land between the surveyed tract and the river where the wells now sit. A special master heard evidence in the receivership case and found for Roberts and Britain; Durfee objected and the exceptions were reviewed by the Court.

Reasoning

The Court examined the original field notes, plats, and patents and concluded the Powell survey called for the river as the northerly boundary. The plat drawings and the phrase “on the south bank of Red River” controlled over a clerical omission in a duplicate record. The Court also found that land later added by natural processes (accretion) became part of the Powell tract, because the riverbank moved naturally. Durfee’s estoppel defense — based on earlier vague plats, a later plat by Roberts, and an asserted statement — failed because the purchaser had record notice of the survey, did not reasonably rely on the vague plats, and the evidence showed no prejudicial reliance.

Real world impact

The Court confirmed the master’s report, denied Durfee’s claim, and directed payment of the royalty interest to Roberts and Britain. The ruling resolves which party gets the oil royalties here, affirms that river calls in old surveys control, and rejects estoppel when buyers relied on the public record rather than vague plats.