Eastland Court Clarifies Property Description Requirements and Depth Limitation Construction in ORRI Assignment Dispute

The Eastland Court of Appeals affirmed partial summary judgment in a multi-party dispute over overriding royalty interests, holding that an assignment's property description exhibit satisfied statute of frauds requirements despite omitting explicit lease listings and that depth limitations in the "leases covering" section applied only to specifically identified leases listed there. The court rejected arguments that missing instruments or property description exhibits rendered the ORRI assignment incomplete or unenforceable, finding that the exhibit did not narrow or limit the broad granting language contained in the assignment itself.