Eighth Court Holds Post-Closing Corrective Assignments Unenforceable Against BFP in Reeves County Overriding Royalty Dispute

In a Reeves County dispute involving 24 oil and gas leases, the El Paso Court of Appeals reversed summary judgment for KWF Enterprises, holding that corrected overriding royalty interest assignments executed in November 2017—which increased KWF's interest from 65% to 100% of KEW Drilling's extra up-to-5% interest—were unenforceable against Callon. The corrected assignments, executed after Callon recorded its interest in August 2017, purported to remedy "scrivener's error and inadvertence" by replacing the 65% allocation in the original pre-closing assignments with 100%, directly impacting Callon's net revenue interest under purchase agreements requiring a "Designated NRI" of 75%.