Oklahoma Statutes
Okla. Stat. tit. 52, § 540 (2026)
Renumbered as § 570.10 of this title by Laws 1992, c. 190,
✓ laws through the 2025 session (checked Sept. 2026)
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§ 28.
Notes of Decisions
Cited in 31
cases (1 in the last 5 years), 1986–2024 · leading case: Hull v. Sun Refining & Mktg. Co., 789 P.2d 1272 (Okla. 1990).
Hull v. Sun Refining & Mktg. Co., 789 P.2d 1272 (Okla. 1990). “The issues presented are: 1) whether a lessor's demonstration of marketable title is sufficient to maintain an action under 52 O.S.Supp. 1985 § 540, [1] providing for the payment of proceeds from oil and gas production; 2) whether lessors are bound by a contract provision…”
Fleet v. Sanguine, Ltd., 854 P.2d 892 (Okla. 1993). “190, § 28) provided: “Any said first purchasers or owner of the right to drill and produce substituted for the first purchaser as provided herein that violates this act [52 O.S.1981 § 540] shall be liable to the persons legally entitled to the proceeds from production for the…”
Seal v. Corp. Comm'n, 725 P.2d 278 (Okla. 1986). “Section 545 provides that distribution of revenue from the sale of production be made pursuant to 52 O.S.Supp.1985 § 540. Additionally, any owner receiving revenues directly from the purchaser must forward the same to the party responsible for distribution under Section 540.”
Heiman v. Atl. Richfield Co., 891 P.2d 1252 (Okla. 1995). “ARCO responds that the 12% interest provision in 52 O.S.Supp. 1980, § 540 was superseded by Rule 6-104(F) of the Oklahoma Corporation Commission, and thus no interest accrued.”
Forest Oil Corp. v. Corp. Com'n of Oklahoma, 807 P.2d 774 (Okla. 1991). “Title 52 O.S.Supp.1985 § 540 [30] requires that distribution to those entitled to proceeds from the sale of oil or gas shall be paid within six months after the first sale.”
Maxwell v. Samson Resources Co., 848 P.2d 1166 (Okla. 1993). “The court included prejudgment interest on those revenues compounded monthly and trebled this total pursuant to 52 O.S.Supp.1985, § 540 and 52 O.S.Supp.1983, §§ 541-47.”
Harrell v. Samson Resources Co., 1998 OK 69, 980 P.2d 99. “Plaintiffs sued for: 1) an accounting under the Sweetheart Gas Act, 52 O.S. § 540 et seq., 2) conversion, and 3) the common law remedy of equitable accounting and cash balancing.”
Purcell v. Santa Fe Minerals, Inc., 1998 OK 45, 961 P.2d 188. “Interest was sought pursuant to 52 O.S.1991 § 540. On February 26, 1987, the version of § 540 provided in part as follows: Any said first purchasers or owner of the right to drill and produce substituted for the first purchaser as provided herein that violates this act shall be…”
Teel v. Pub. Serv. Co. of Oklahoma, 767 P.2d 391 (Okla. 1987). “*399 Teel contends he is entitled to recover interest at the rate of six percent per an-num on the gas purchased until it was paid into escrow — with the exception that money paid into escrow after July 1, 1980, should draw interest at the rate of 12% under 52 O.S.1981 § 540. 23…”
Quinlan v. Koch Oil Co., 25 F.3d 936 (10th Cir. 1994). “In the district court, Quinlan claimed he was entitled to interest at the annual rate of twelve percent, compounded annually, pursuant to Okla.Stat. tit. 52, § 540 D. 2 The district court agreed, and in an order granting Quinlan’s motion for partial summary judgment, the…”
McClain v. Ricks Expl. Co., 894 P.2d 422 (Okla. Civ. App. 1994). “The trial court determined all Defendants who are working interest owners, including Ricks, are liable under 52 O.S.1981, § 540 to Plaintiffs for the working interest wrongfully paid to them by Ricks plus 12% interest.”
Okland Oil Co. v. Conoco Inc., 144 F.3d 1308 (10th Cir. 1998). “The predecessor statute, Okla. Stat. tit. 52, § 540 (1991), contained essentially the same language.”
Okla. Stat. tit. 52, § 540(A): 5 cases
Fleet v. Sanguine, Ltd., 854 P.2d 892 (Okla. 1993). “190, § 28) provided: “Any said first purchasers or owner of the right to drill and produce substituted for the first purchaser as provided herein that violates this act [52 O.S.1981 § 540] shall be liable to the persons legally entitled to the proceeds from production for the…”
Goodall v. Trigg Drilling Co., 1997 OK 74, 944 P.2d 292.
Maxwell v. Samson Resources Co., 848 P.2d 1166 (Okla. 1993). “The court included prejudgment interest on those revenues compounded monthly and trebled this total pursuant to 52 O.S.Supp.1985, § 540 and 52 O.S.Supp.1983, §§ 541-47.”
Shearn v. Ward Petroleum Corp., 808 F. Supp. 1530 (W.D. Okla. 1992).
Mayo v. Kaiser-Francis Oil Co., 1998 OK CIV APP 94, 962 P.2d 657.
Okla. Stat. tit. 52, § 540(B): 7 cases
Fleet v. Sanguine, Ltd., 854 P.2d 892 (Okla. 1993). “190, § 28) provided: “Any said first purchasers or owner of the right to drill and produce substituted for the first purchaser as provided herein that violates this act [52 O.S.1981 § 540] shall be liable to the persons legally entitled to the proceeds from production for the…”
Hull v. Sun Refining & Mktg. Co., 789 P.2d 1272 (Okla. 1990). “The issues presented are: 1) whether a lessor's demonstration of marketable title is sufficient to maintain an action under 52 O.S.Supp. 1985 § 540, [1] providing for the payment of proceeds from oil and gas production; 2) whether lessors are bound by a contract provision…”
Purcell v. Santa Fe Minerals, Inc., 1998 OK 45, 961 P.2d 188. “Interest was sought pursuant to 52 O.S.1991 § 540. On February 26, 1987, the version of § 540 provided in part as follows: Any said first purchasers or owner of the right to drill and produce substituted for the first purchaser as provided herein that violates this act shall be…”
Maxwell v. Samson Resources Co., 848 P.2d 1166 (Okla. 1993). “The court included prejudgment interest on those revenues compounded monthly and trebled this total pursuant to 52 O.S.Supp.1985, § 540 and 52 O.S.Supp.1983, §§ 541-47.”
Schommer v. Communicate Now!, L.P., 2014 OK CIV APP 38.
Okla. Stat. tit. 52, § 540(C): 1 case
Purcell v. Santa Fe Minerals, Inc., 1998 OK 45, 961 P.2d 188. “Interest was sought pursuant to 52 O.S.1991 § 540. On February 26, 1987, the version of § 540 provided in part as follows: Any said first purchasers or owner of the right to drill and produce substituted for the first purchaser as provided herein that violates this act shall be…”
Okla. Stat. tit. 52, § 540(D): 1 case
Purcell v. Santa Fe Minerals, Inc., 1998 OK 45, 961 P.2d 188. “Interest was sought pursuant to 52 O.S.1991 § 540. On February 26, 1987, the version of § 540 provided in part as follows: Any said first purchasers or owner of the right to drill and produce substituted for the first purchaser as provided herein that violates this act shall be…”
Okla. Stat. tit. 52, § 540(D)(1989): 1 case
Cockerell Oil Props., Ltd. v. Unit Petroleum Co., No. 6:16-cv-00135 (E.D. Okla. May 4, 2020).
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