Oil & Gas Litigation Analysis

Title Disputes

Title Disputes

Texas Supreme Court Overturns Decades of Precedent on Subject Matter Jurisdiction Over Foreign Mineral Rights

Joel Reese | Jun 02, 2026

The Texas Supreme Court reversed the Fort Worth Court of Appeals and disapproved six prior decisions, holding that Texas courts have subject matter jurisdiction over in personam claims involving West Virginia mineral rights where the defendant is subject to personal jurisdiction in Texas. The Court rejected the 'gist of the action' test that had barred Texas courts from adjudicating disputes where title to foreign property was central to the claims.