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Conoco Phillips v. Ramirez

In 1941, Ramirez died leaving his children 7,016 acres in multiple tracts, including a tract known as Ranch 'Las Piedras'.

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Argued September 17, 2019 CHIEF JUSTICE HECHT delivered the opinion of the Court. The issue we decide in this case is whether a devise of “all . . . right, title and interest in and to Ranch ‘Las Piedras’” refers only to a surface estate by that name as understood by the testatrix and beneficiaries at the time the will was made or also includes the mineral estate. We conclude that only the surface estate was devised. We reverse the court of appeals’ judgment and render judgment for petitioners. I Conveyances over 80 years provide the context for the parties’ dispute. The factual background is lengthy and complex but in all material respects undisputed. To assist the reader’s understanding, we will both describe and chart the transactions. A complete chart is included in an appendix. All fractions are undivided interests. In 1941, Ildefonso Ramirez died, leaving to his children, Leon Juan and Felicidad, multiple tracts totaling 7,016 acres in Zapata County. Not all of the tracts were contiguous. Months later, Leon Juan and Felicidad partitioned the surface estate and severed the minerals, each taking 3,508 surface acres and an undivided 1/2 interest in the minerals under the entire 7,016 acres. As a result:

Ildefonso Ramirez’s 7,016 acres 1941: Ildefonso’s death1/2 Leon Juan & 1/2 Felicidad

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