Texas Fourth Court Resolves Century-Old Deed Ambiguity: Fixed NPRI vs. Floating Mineral Interest in Webb County Ranch

The Fourth Court of Appeals affirmed summary judgment construing a 1937 Webb County ranch deed reservation as a 1/32 non-executive mineral interest with floating royalty (1/32 of the 1/6 lease royalty), rejecting the Esperanza Successors' claim to a fixed 1/32 NPRI despite decades of operator payment practices treating it as fixed royalty. The court rejected presumed-grant doctrine arguments and equitable defenses including laches and quasi-estoppel, holding that the deed's express language—reserving "an undivided One-Thirty-second (1/32) of all oil, gas and other minerals"—unambiguously created a mineral interest rather than a non-participating royalty interest.