Energy & Environmental Law Blog

Energy & Environmental Law Blog

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Tag Archives: Implied Covenants

OH: Some New Cases

Posted in Energy
We thought you might be interested in the following cases out of Ohio: Blazek v. Reserve Energy Exploration (Belmont C.P.):  Finding, for example, that the payment of annual delay rentals during the primary term negates the implied covenant to develop (at least during that period); and that the lessee has no duty to disclose the "true… Continue Reading

No Implied Duty to Develop Marcellus

Posted in Energy
So holds the Pennsylvania Superior Court in Caldwell v. Kriebel Resources Co., No. 1305-WDA-2012 (June 21, 2013).  Plaintiffs sued because the operator’s drilling activities involved only shallow formations to date, and did not involve exploring for or producing the Marcellus Shale.  Among other things, the court rejected the plaintiffs’ claim that the operator had an… Continue Reading