Crawford v. XTO Energy, Inc

An oil-and-gas lessor sued the lessee for failure to pay royalties. The trial court concluded that the lessor’s neighboring landowners were necessary parties to the suit and dismissed the case without prejudice because the lessor failed to join them. The court of appeals affirmed, concluding that the trial court did not abuse its discretion in requiring joinder. The Supreme Court reversed, holding that the trial court abuse its discretion in requiring joinder under Tex. R. Civ. P. 39 and dismissing the case because the adjacent landowners did not claim an interest relating to the subject of the lessor’s suit against the lessee. Remanded for further proceedings. View "Crawford v. XTO Energy, Inc" on Justia Law