Louisiana Revised Statutes & Codes
La. Rev. Stat. § 30:9 (2026)
✓ current as of May 2026
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§9. Production from pool; drilling units; equitable share; rules and regulations
Notes of Decisions
Cited in 66
cases (11 in the last 5 years), 1952–2025 · leading case: Peironnet v. Matador Resources Co., 144 So. 3d 791 (La. 2013).
Peironnet v. Matador Resources Co., 144 So. 3d 791 (La. 2013). “See La.Rev.Stat. § 30:9(B)(“For the prevention of waste and to avoid the drilling of unnecessary wells, the commissioner shall establish a drilling unit or units for each pool.”
Nunez v. Wainoco Oil & Gas Co., 488 So. 2d 955 (La. 1986). “As will be developed later in this opinion, it was in response to such a situation that the Commissioner of Conservation was empowered by La.Rev.Stat.Ann. § 30:9 B to establish drilling units, defined as "the maximum area which may be efficiently and economically drained by one…”
Amoco Prod. Co. v. Thompson, 516 So. 2d 376 (La. Ct. App. 1987). “1982) as follows: `Unit' means an area of land, deposit, or deposits of minerals, stratum or strata, or pool or pools, or a part or parts thereof, as to which parties with interests therein are bound to share minerals produced on a specified basis and as to which those having…”
Hunt Oil Co. v. Batchelor, 644 So. 2d 191 (La. 1994). “R.S. 30:9(B) and 30:10(A). The primary duty of the Commissioner is to prevent waste of the state's mineral *197 resources by exercising his authority to promote the full and efficient development of these resources.”
B A Kelly Land v. Aethon Energy, 25 F.4th 369 (5th Cir. 2022). “R.S. 30:9(B). Unitization enables the Commissioner to authorize an operator to establish an oil and gas claim and, after giving notice and an opportunity for Kelly to respond, sua sponte rendered partial summary judgment in favor of Aethon and dismissed both of Kelly’s…”
T D X Energy, L.L.C. v. Chesapeake Operating, Inc., 857 F.3d 253 (5th Cir. 2017). “Louisiana is one such state. Its Commissioner of Conservation designates drilling units whenever necessary to prevent waste or avoid needless drilling, even if owners of oil and gas interests have not agreed to pool their interests.”
Childs v. Washington, 87 So. 2d 111 (La. 1956). “, requires that the Commissioner of Conservation, if he finds it necessary in order to prevent waste and to avoid drilling unnecessary wells, "shall establish a drilling unit or units for each pool", LSA-R.S. 30:9, subd. B [7] and contains the provision that owners may validly…”
Delatte v. Woods, 94 So. 2d 281 (La. 1957). “8(b) of Act 157 of 1940, as amended, LSA-R.S. 30:9(B), authorizes the commissioner to establish drilling units so as to prevent waste and to avoid the drilling of unnecessary wells.”
Hunter v. Hussey, 90 So. 2d 429 (La. Ct. App. 1957). “" To complete the statutory standards, LSA-R.S. 30:9, subd. D, which defines the producer's "just and equitable share", provides as follows: "Subject to the reasonable necessities for the prevention of waste, and to reasonable adjustment because of structural position, a…”
Mire v. Hawkins, 186 So. 2d 591 (La. 1966). “" R.S. 30:9 B and C. But, "the owner [9] of a tract of land in the pool, in order that he may obtain the tract's just and equitable share of the production of the pool," cannot be compelled under any order, rule, or regulation of the commissioner, either in its specific "terms…”
Corbello v. Sutton, 442 So. 2d 610 (La. Ct. App. 1983). “-R.S. 30:9 mandates that the principle of counter drainage is constitutionally required.”
Rebstock v. Birthright Oil & Gas Co., 406 So. 2d 636 (La. Ct. App. 1981). “8(b) of Act 157 of 1940, as amended, LSA-R.S. 30:9(B), authorizes the commissioner to establish drilling units so as to prevent waste and to avoid the drilling of unnecessary wells.”
— La. Rev. Stat. § 30:9(A) — 2 cases
James Self Wilma Self v. Bpx Operating Co. (La. 2024).
James Self Wilma Self v. Bpx Operating Co. (La. 2024).
— La. Rev. Stat. § 30:9(B) — 30 cases
Peironnet v. Matador Resources Co., 144 So. 3d 791 (La. 2013). “See La.Rev.Stat. § 30:9(B)(“For the prevention of waste and to avoid the drilling of unnecessary wells, the commissioner shall establish a drilling unit or units for each pool.”
B A Kelly Land v. Aethon Energy, 25 F.4th 369 (5th Cir. 2022). “R.S. 30:9(B). Unitization enables the Commissioner to authorize an operator to establish an oil and gas claim and, after giving notice and an opportunity for Kelly to respond, sua sponte rendered partial summary judgment in favor of Aethon and dismissed both of Kelly’s…”
T D X Energy, L.L.C. v. Chesapeake Operating, Inc., 857 F.3d 253 (5th Cir. 2017). “Louisiana is one such state. Its Commissioner of Conservation designates drilling units whenever necessary to prevent waste or avoid needless drilling, even if owners of oil and gas interests have not agreed to pool their interests.”
Amoco Prod. Co. v. Thompson, 516 So. 2d 376 (La. Ct. App. 1987). “1982) as follows: `Unit' means an area of land, deposit, or deposits of minerals, stratum or strata, or pool or pools, or a part or parts thereof, as to which parties with interests therein are bound to share minerals produced on a specified basis and as to which those having…”
Delatte v. Woods, 94 So. 2d 281 (La. 1957). “8(b) of Act 157 of 1940, as amended, LSA-R.S. 30:9(B), authorizes the commissioner to establish drilling units so as to prevent waste and to avoid the drilling of unnecessary wells.”
— La. Rev. Stat. § 30:9(C) — 2 cases
Six C Props., LLC v. Welsh, 68 So. 3d 609 (La. Ct. App. 2011).
Trunkline Gas Co. v. Steen, 179 So. 2d 546 (La. Ct. App. 1965).
— La. Rev. Stat. § 30:9(D) — 5 cases
Amoco Prod. Co. v. Thompson, 516 So. 2d 376 (La. Ct. App. 1987). “1982) as follows: `Unit' means an area of land, deposit, or deposits of minerals, stratum or strata, or pool or pools, or a part or parts thereof, as to which parties with interests therein are bound to share minerals produced on a specified basis and as to which those having…”
Hunt Oil Co. v. Batchelor, 644 So. 2d 191 (La. 1994). “R.S. 30:9(B) and 30:10(A). The primary duty of the Commissioner is to prevent waste of the state's mineral *197 resources by exercising his authority to promote the full and efficient development of these resources.”
Mobil Oil Corp. v. Gill, 194 So. 2d 351 (La. Ct. App. 1967).
Exxon Corp. v. Thompson, 564 So. 2d 387 (La. Ct. App. 1990).
Minor v. Pan Am. Petroleum Corp., 216 F. Supp. 86 (W.D. La. 1962).
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