Eastland Court Affirms TCPA Dismissal of Slander-of-Title Claim Based on Railroad Commission Drilling Permit Applications

The Eastland Court of Appeals affirmed dismissal under the Texas Citizens Participation Act of Horizontal Development Partners' slander-of-title claim against Endeavor Energy Resources, holding that statements in drilling permit applications to the Texas Railroad Commission constituted protected petitioning activity. The court found Horizontal failed to produce clear and specific evidence that Endeavor falsely claimed ownership of deep rights or acted with malice when completing permit applications.