Texas Supreme Court Clarifies That NPRI Fixed Fractional Interests Are Not Reduced by Lease Ratification but May Be Modified by Cross-Conveyance

Texas Supreme Court holds that a non-participating royalty interest holder's fixed 1/8 fractional interest in production was not reduced when the working interest owner ratified a subsequent lease containing a 1/4 landowner royalty, reaffirming Hysaw v. Dawkins that NPRIs convey a fixed share of gross production rather than a floating fraction of the lease royalty. The Court reversed the court of appeals on separate grounds, however, holding that the NPRI was later reduced through stipulation and cross-conveyance under Concho Resources v. Ellison, distinguishing between automatic ratification effects and voluntary conveyances that modify royalty interests.