A Louisiana statute requires a well operator to provide landowners “a sworn, detailed, [and] itemized statement” about drilling costs. Brannon Properties v. Chesapeake Operating, No. 12-30306 (Feb. 21, 2013, unpublished). The Fifth Circuit reversed a summary judgment for the operator, finding that the district court correctly concluded that its report lacked enough detail under the unambiguous language of the statute, and that the analysis should have ended there. Id. at 5 (“The statute clearly connects the costs reported to the benefits received in exchange. . . . [I]t must tell the unleased mineral owner what it is getting for its money.”). The Court faulted the district court for proceeding to analysis of the statute’s purpose after reaching a conclusion that its terms were unambiguous, and also for finding an incorrect purpose inconsistent with those terms. Id. at 6-7.
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