Oklahoma v. Texas

1920-04-01
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Headline: United States allowed to intervene, court blocks Texas from selling specified Red River riverbed lands and appoints a receiver to take charge of oil and gas operations on those lands.

Holding: The Court allowed the United States to intervene, enjoined Texas from selling or granting rights to Red River bed lands north of the 1821 south-bank line, and appointed a receiver to manage oil and gas there.

Real World Impact:
  • Blocks Texas from selling or granting rights to specified Red River bed lands.
  • Court-appointed receiver will manage oil and gas production and sell output at market prices.
  • Current holders must yield possession and cannot operate wells without receiver’s supervision.
Topics: riverbed land disputes, state property claims, oil and gas operations, federal intervention

Summary

Background

The United States moved to intervene in a dispute between the State of Oklahoma and the State of Texas over parts of the Red River bed. Oklahoma had brought the issue to court, and the United States asked for permission to join and for the court to stop Texas from selling or issuing rights over certain lands north of the river’s south bank as that bank existed on February 22, 1821. The court granted the United States leave to intervene and named Jacob M. Dickinson as the court-appointed receiver for the specified lands.

Reasoning

The court addressed whether intervention, an injunction against Texas selling or granting rights, and a receivership were appropriate to protect the lands and their oil and gas. The court enjoined Texas from selling or issuing grants or permits that would affect the described riverbed lands and defined the area by reference to the 1821 south-bank line and geographic markers. The receiver was given power to take immediate possession, conserve oil and gas, control operations, operate or close wells, sell production at market prices, and keep separate accounts so net proceeds can later be awarded to the rightful claimant. The receiver must post a $100,000 bond and report a plan for prospecting and development within thirty days.

Real world impact

Practically, Texas cannot sell or lease the described riverbed lands while this order stands. Current occupants and claimants must deliver possession and may not remove property or run oil and gas operations except under the receiver’s supervision. The receiver will run or supervise production and handle income and expenses pending further court orders. The order is an interim, protective step and does not finally determine ownership; interested parties may be added and Texas may file responses about lands it does not claim as state property.

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