District Court Dismisses State Land Conveyance Claims Against Diamondback, Holds Texas Relinquishment Act Inapplicable to 1948 Land Sales Act Conveyance

Williams O&G Resources challenged Diamondback Energy's mineral development under the Texas Relinquishment Act of 1919, but the Western District of Texas held the Act inapplicable where land was conveyed from the State in 1948 under the Texas Land Sales Act of 1931. The court rejected Williams O&G's novel interpretation of the 1937 Wintermann decision, holding that land sold under the Land Sales Act is governed by its own terms, not by the Relinquishment Act.