Louisiana Revised Statutes & Codes

La. Rev. Stat. § 31:9 (2026)

Correlative rights of owners of common reservoir or deposit

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§9. Correlative rights of owners of common reservoir or deposit

Landowners and others with rights in a common reservoir or deposit of minerals have correlative rights and duties with respect to one another in the development and production of the common source of minerals.

Acts 1974, No. 50, §1, eff. Jan. 1, 1975.

Notes of Decisions

Cited in 9 cases, 1986–2014 · leading case: Amoco Prod. Co. v. Thompson, 516 So. 2d 376 (La. Ct. App. 1987).

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Amoco Prod. Co. v. Thompson, 516 So. 2d 376 (La. Ct. App. 1987). · cites it 3× “La.Rev.Stat.Ann. § 31:9 and 10. As noted by a scholar on the subject, `[t]he principles of private ownership which involve dominion on the part of the landowner over all substances from the center of the earth to the heavens were inadequate to solve the problems of a substance…”

Nunez v. Wainoco Oil & Gas Co., 488 So. 2d 955 (La. 1986). · cites it 2× “La.Rev. Stat.Ann. § 31:9 and 10. As noted by a scholar on the subject, "[t]he principles of private ownership which involve dominion on the part of the landowner over all substances from the center of the earth to the heavens were inadequate to solve the problems of a substance…”

Hunt Oil Co. v. Batchelor, 644 So. 2d 191 (La. 1994). · cites it 2× “R.S. 31:9, 10, and 11], the Commissioner has the authority to modify or deny the right to take in kind.”

Amoco Prod. Co. v. Thompson, 566 So. 2d 138 (La. Ct. App. 1990). · cites it 2× “R.S. 31:9, 10 and 11), the Commission has the authority to modify or deny the right to take in kind.”

Breton Energy, L.L.C. v. Mariner Energy Resources, Inc., 764 F.3d 394 (5th Cir. 2014). · cites it 2× “16 In turn, Article 9 establishes the correlative rights of landowners in a common reservoir, “Landowners and others with rights in a common reservoir or deposit of minerals have correlative rights and duties with respect to one another in the development and production of the…”

Nunez v. Wainoco Oil & Gas Co., 606 So. 2d 1320 (La. Ct. App. 1992). · cites it 2× “La.Rev.Stat.Ann.§ 31:9 and 10. As noted by a scholar on the subject, `[t]he principles of private ownership which involve dominion on the part of the landowner over all substances from the center of the earth to the heavens were inadequate to solve the problems of a substance…”

Ellwood Oil Co. v. Anderson, 655 So. 2d 694 (La. Ct. App. 1995). “2d 693 (1955); LRS 31:9, 10. Because of the absence of a specific agreement, general principles of co-ownership are applicable here.”

Tex/Con Oil & Gas Co. v. Batchelor, 634 So. 2d 902 (La. Ct. App. 1993). “LSA-R.S. 31:9, 10; Thompson II, 566 So.2d at 146 .”

Exxon Corp. v. Thompson, 564 So. 2d 387 (La. Ct. App. 1990). · cites it 3× “La.Rev. Stat.Ann. § 31:9 and 10. As noted by a scholar on the subject, `[t]he principles of private ownership which involve dominion on the part of the landowner over all substances from the center of the earth to the heavens were inadequate to solve the problems of a substance…”

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