Eastland Court Reverses Enforcement of Mediated Settlement Agreement Over Ambiguous JOA Terms

The Eastland Court of Appeals reversed summary judgment enforcing a mediated settlement agreement in a mineral interest title dispute, holding that ambiguities in the MSA precluded enforcement where the parties disputed whether one party could unilaterally populate unresolved terms in model form joint operating agreements. The court further held that Rustic Natural Resources was not bound by specific JOA terms tendered by DE Midland and Endeavor Energy because the MSA did not include specific JOA terms and did not authorize either party to unilaterally complete or select options in the model JOA form.