Louisiana Revised Statutes & Codes
La. Rev. Stat. § 30:10 (2026)
✓ current as of May 2026
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§10. Agreements for drilling units; pooling interests; terms and conditions; expenses
Notes of Decisions
Cited in 76
cases (14 in the last 5 years), 1952–2025 · leading case: King v. Strohe, 673 So. 2d 1329 (La. Ct. App. 1996).
King v. Strohe, 673 So. 2d 1329 (La. Ct. App. 1996). “R.S. 30:10(A)(3) to the facts of this case.”
T D X Energy, L.L.C. v. Chesapeake Operating, Inc., 857 F.3d 253 (5th Cir. 2017). “R.S. § 30:10(A)(2). To prevent free riding, the statute creates a mechanism for sharing the risk that a well, once drilled, will not produce enough to cover drilling costs.”
Taylor v. Smith, 619 So. 2d 881 (La. Ct. App. 1993). “" *886 The trial court, in determining that under any theory of recovery, the Taylors' cause of action had prescribed, stated, in its reasons for judgment, as follows: "Petitioners base their argument on LSA R.S. 30:10(3) that reads: "If there is included in any unit created by…”
Amoco Prod. Co. v. Thompson, 516 So. 2d 376 (La. Ct. App. 1987). “La.Rev.Stat.Ann. § 30:10 A(1).... Like the Oklahoma Supreme Court, we conclude that the established principles of private ownership, already found inadequate in Louisiana to deal with the problems of subsurface fugacious minerals ( see Daggett, supra at 415), need not…”
B A Kelly Land v. Aethon Energy, 25 F.4th 369 (5th Cir. 2022). “R.S. 30:10(A)(1)(b)). Consequently, the Louisiana Supreme Court has held that “the more recent legislative enactments of Title 30 [the Conservation Act] and Title 31 [the Mineral Code] supersede in part La.”
Taylor v. Woodpecker Corp., 562 So. 2d 888 (La. 1990). “The Taylors claim that order 24-D effectively pooled the mineral interests in the separate tracts in Unit 71B under the authority of LSA-R.S. 30:10, which states in pertinent part: A.”
Self v. B P X Operating, 80 F.4th 632 (5th Cir. 2023). “R.S. 30:10(A)(2)(b)(i), (e)(i); B.A. Kelly, 25 F.”
Hunt Oil Co. v. Batchelor, 644 So. 2d 191 (La. 1994). “R.S. 30:10(A)(1). All orders forming compulsory units "shall be upon terms and conditions that are just and reasonable and that will afford the owner of each tract the opportunity to recover or receive his just and equitable share of the oil and gas in the pool without…”
Nunez v. Wainoco Oil & Gas Co., 488 So. 2d 955 (La. 1986). “Therefore, we must consider whether the formation of a compulsory unit, as permitted in La.Rev.Stat.Ann. § 30:10, affects the generally applicable principles concerning ownership of property and/or alters the concept of trespass beneath the surface owner's tract.”
Taylor v. David New Operating Co., Inc., 619 So. 2d 1251 (La. Ct. App. 1993). “Essentially, the operator is entitled to sell the owner's proportionate share of production, but the operator must pay the owner within 180 days of the sale or found to be in breach of the statutory authorization to sell expressly set out in LSA-R.S. 30:10(A). See also Northcott…”
Tex/Con Oil & Gas Co. v. Batchelor, 634 So. 2d 902 (La. Ct. App. 1993). “This case is before us on appeal from a judgment of the trial court which declared that, as a matter of law, LSA-R.S. 30:10 A(2) and the custom and usage of the oil and gas industry require that the unit of production depreciated well cost method of accounting be applied to…”
Johnson v. Chesapeake Louisiana, L.P., 87 F.4th 305 (5th Cir. 2023). “R.S. 30:10(A)(2)(b)(i), (e)(i); B.A. Kelly, 25 F.”
— La. Rev. Stat. § 30:10(3) — 2 cases
Taylor v. Smith, 619 So. 2d 881 (La. Ct. App. 1993). “" *886 The trial court, in determining that under any theory of recovery, the Taylors' cause of action had prescribed, stated, in its reasons for judgment, as follows: "Petitioners base their argument on LSA R.S. 30:10(3) that reads: "If there is included in any unit created by…”
Taylor v. Woodpecker Corp., 552 So. 2d 81 (La. Ct. App. 1990).
— La. Rev. Stat. § 30:10(A) — 10 cases
Taylor v. Smith, 619 So. 2d 881 (La. Ct. App. 1993). “" *886 The trial court, in determining that under any theory of recovery, the Taylors' cause of action had prescribed, stated, in its reasons for judgment, as follows: "Petitioners base their argument on LSA R.S. 30:10(3) that reads: "If there is included in any unit created by…”
Taylor v. David New Operating Co., Inc., 619 So. 2d 1251 (La. Ct. App. 1993). “Essentially, the operator is entitled to sell the owner's proportionate share of production, but the operator must pay the owner within 180 days of the sale or found to be in breach of the statutory authorization to sell expressly set out in LSA-R.S. 30:10(A). See also Northcott…”
Sw. Gas Producing Co. v. Creslenn Oil Co., 181 So. 2d 63 (La. Ct. App. 1966).
Taylor v. Woodpecker Corp., 633 So. 2d 1308 (La. Ct. App. 1994).
Mire v. Hawkins, 177 So. 2d 795 (La. Ct. App. 1965).
— La. Rev. Stat. § 30:10(A)(1) — 4 cases
Northcott Expl. Co. v. WR Grace & Co., 430 So. 2d 1077 (La. Ct. App. 1983).
Amoco Prod. Co. v. Thompson, 516 So. 2d 376 (La. Ct. App. 1987). “La.Rev.Stat.Ann. § 30:10 A(1).... Like the Oklahoma Supreme Court, we conclude that the established principles of private ownership, already found inadequate in Louisiana to deal with the problems of subsurface fugacious minerals ( see Daggett, supra at 415), need not…”
Hunt Oil Co. v. Batchelor, 644 So. 2d 191 (La. 1994). “R.S. 30:10(A)(1). All orders forming compulsory units "shall be upon terms and conditions that are just and reasonable and that will afford the owner of each tract the opportunity to recover or receive his just and equitable share of the oil and gas in the pool without…”
Exxon Corp. v. Thompson, 564 So. 2d 387 (La. Ct. App. 1990).
— La. Rev. Stat. § 30:10(A)(1)(a) — 7 cases
Hunt Oil Co. v. Batchelor, 644 So. 2d 191 (La. 1994). “R.S. 30:10(A)(1). All orders forming compulsory units "shall be upon terms and conditions that are just and reasonable and that will afford the owner of each tract the opportunity to recover or receive his just and equitable share of the oil and gas in the pool without…”
Amoco Prod. Co. v. Thompson, 516 So. 2d 376 (La. Ct. App. 1987). “La.Rev.Stat.Ann. § 30:10 A(1).... Like the Oklahoma Supreme Court, we conclude that the established principles of private ownership, already found inadequate in Louisiana to deal with the problems of subsurface fugacious minerals ( see Daggett, supra at 415), need not…”
Amoco Prod. Co. v. Thompson, 566 So. 2d 138 (La. Ct. App. 1990).
Exxon Corp. v. Thompson, 564 So. 2d 387 (La. Ct. App. 1990).
Dow Constr. L L C v. B P X Operating Co (W.D. La. 2021).
— La. Rev. Stat. § 30:10(A)(1)(b) — 6 cases
B A Kelly Land v. Aethon Energy, 25 F.4th 369 (5th Cir. 2022). “R.S. 30:10(A)(1)(b)). Consequently, the Louisiana Supreme Court has held that “the more recent legislative enactments of Title 30 [the Conservation Act] and Title 31 [the Mineral Code] supersede in part La.”
Frey v. Miller, 165 So. 2d 43 (La. Ct. App. 1964).
Self v. B P X Operating Co (W.D. La. 2022).
Johnson v. Chesapeake Louisiana L P (W.D. La. 2022).
Dow Constr. L L C v. B P X Operating Co (W.D. La. 2021).
— La. Rev. Stat. § 30:10(A)(1)(c) — 4 cases
Davis Oil v. Steamboat Petroleum, 583 So. 2d 1139 (La. 1991).
Scurlock Oil Co. v. Getty Oil Co., 344 So. 2d 1134 (La. Ct. App. 1977).
Shanks v. Exxon Corp., 674 So. 2d 473 (La. Ct. App. 1996).
Jones Energy Co. v. Chesapeake Louisiana, L.P., 873 F. Supp. 2d 779 (W.D. La. 2012).
— La. Rev. Stat. § 30:10(A)(2) — 8 cases
T D X Energy, L.L.C. v. Chesapeake Operating, Inc., 857 F.3d 253 (5th Cir. 2017). “R.S. § 30:10(A)(2). To prevent free riding, the statute creates a mechanism for sharing the risk that a well, once drilled, will not produce enough to cover drilling costs.”
James Self Wilma Self v. Bpx Operating Co. (La. 2024).
James Self Wilma Self v. Bpx Operating Co. (La. 2024).
Dow Constr. L L C v. B P X Operating Co (W.D. La. 2021).
Self v. B P X Operating Co (W.D. La. 2022).
— La. Rev. Stat. § 30:10(A)(2)(a)(i) — 10 cases
T D X Energy, L.L.C. v. Chesapeake Operating, Inc., 857 F.3d 253 (5th Cir. 2017). “R.S. § 30:10(A)(2). To prevent free riding, the statute creates a mechanism for sharing the risk that a well, once drilled, will not produce enough to cover drilling costs.”
B A Kelly Land v. Aethon Energy, 25 F.4th 369 (5th Cir. 2022). “R.S. 30:10(A)(1)(b)). Consequently, the Louisiana Supreme Court has held that “the more recent legislative enactments of Title 30 [the Conservation Act] and Title 31 [the Mineral Code] supersede in part La.”
Dow Constr. L L C v. B P X Operating Co (W.D. La. 2022).
Jones Energy Co. v. Chesapeake Louisiana, L.P., 873 F. Supp. 2d 779 (W.D. La. 2012).
Dow Constr. L L C v. B P X Operating Co (W.D. La. 2021).
— La. Rev. Stat. § 30:10(A)(2)(b)(i) — 9 cases
B A Kelly Land v. Aethon Energy, 25 F.4th 369 (5th Cir. 2022). “R.S. 30:10(A)(1)(b)). Consequently, the Louisiana Supreme Court has held that “the more recent legislative enactments of Title 30 [the Conservation Act] and Title 31 [the Mineral Code] supersede in part La.”
T D X Energy, L.L.C. v. Chesapeake Operating, Inc., 857 F.3d 253 (5th Cir. 2017). “R.S. § 30:10(A)(2). To prevent free riding, the statute creates a mechanism for sharing the risk that a well, once drilled, will not produce enough to cover drilling costs.”
Self v. B P X Operating, 80 F.4th 632 (5th Cir. 2023). “R.S. 30:10(A)(2)(b)(i), (e)(i); B.A. Kelly, 25 F.”
Johnson v. Chesapeake Louisiana, L.P., 87 F.4th 305 (5th Cir. 2023). “R.S. 30:10(A)(2)(b)(i), (e)(i); B.A. Kelly, 25 F.”
Jones Energy Co. v. Chesapeake Louisiana, L.P., 873 F. Supp. 2d 779 (W.D. La. 2012).
— La. Rev. Stat. § 30:10(A)(2)(b)(ii) — 1 case
Jones Energy Co. v. Chesapeake Louisiana, L.P., 873 F. Supp. 2d 779 (W.D. La. 2012).
— La. Rev. Stat. § 30:10(A)(2)(c) — 1 case
T D X Energy, L.L.C. v. Chesapeake Operating, Inc., 857 F.3d 253 (5th Cir. 2017). “R.S. § 30:10(A)(2). To prevent free riding, the statute creates a mechanism for sharing the risk that a well, once drilled, will not produce enough to cover drilling costs.”
— La. Rev. Stat. § 30:10(A)(2)(e) — 2 cases
T D X Energy, L.L.C. v. Chesapeake Operating, Inc., 857 F.3d 253 (5th Cir. 2017). “R.S. § 30:10(A)(2). To prevent free riding, the statute creates a mechanism for sharing the risk that a well, once drilled, will not produce enough to cover drilling costs.”
Dow Constr. v. B P X Operating, 140 F.4th 246 (5th Cir. 2025).
— La. Rev. Stat. § 30:10(A)(2)(e)(i) — 7 cases
B A Kelly Land v. Aethon Energy, 25 F.4th 369 (5th Cir. 2022). “R.S. 30:10(A)(1)(b)). Consequently, the Louisiana Supreme Court has held that “the more recent legislative enactments of Title 30 [the Conservation Act] and Title 31 [the Mineral Code] supersede in part La.”
Dow Constr. L L C v. B P X Operating Co (W.D. La. 2021).
Dow Constr. L L C v. B P X Operating Co (W.D. La. 2022).
Self v. B P X Operating Co (W.D. La. 2022).
Johnson v. Chesapeake Louisiana L P (W.D. La. 2022).
— La. Rev. Stat. § 30:10(A)(2)(f) — 4 cases
T D X Energy, L.L.C. v. Chesapeake Operating, Inc., 857 F.3d 253 (5th Cir. 2017). “R.S. § 30:10(A)(2). To prevent free riding, the statute creates a mechanism for sharing the risk that a well, once drilled, will not produce enough to cover drilling costs.”
Mills v. Davis Oil Co., 11 F.3d 1298 (5th Cir. 1994).
Jones Energy Co. v. Chesapeake Louisiana, L.P., 873 F. Supp. 2d 779 (W.D. La. 2012).
Mills, III v. Davis Oil Co., 11 F.3d 1298 (5th Cir. 1994).
— La. Rev. Stat. § 30:10(A)(3) — 31 cases
King v. Strohe, 673 So. 2d 1329 (La. Ct. App. 1996). “R.S. 30:10(A)(3) to the facts of this case.”
Taylor v. Smith, 619 So. 2d 881 (La. Ct. App. 1993). “" *886 The trial court, in determining that under any theory of recovery, the Taylors' cause of action had prescribed, stated, in its reasons for judgment, as follows: "Petitioners base their argument on LSA R.S. 30:10(3) that reads: "If there is included in any unit created by…”
Taylor v. Woodpecker Corp., 562 So. 2d 888 (La. 1990). “The Taylors claim that order 24-D effectively pooled the mineral interests in the separate tracts in Unit 71B under the authority of LSA-R.S. 30:10, which states in pertinent part: A.”
Self v. B P X Operating, 80 F.4th 632 (5th Cir. 2023). “R.S. 30:10(A)(2)(b)(i), (e)(i); B.A. Kelly, 25 F.”
Taylor v. David New Operating Co., Inc., 619 So. 2d 1251 (La. Ct. App. 1993). “Essentially, the operator is entitled to sell the owner's proportionate share of production, but the operator must pay the owner within 180 days of the sale or found to be in breach of the statutory authorization to sell expressly set out in LSA-R.S. 30:10(A). See also Northcott…”
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