Patterson v. Stanolind Oil & Gas Co., 305 U.S. 376 (1939)
U.S. Supreme CourtPatterson v. Stanolind Oil & Gas Co., 305 U.S. 376 (1939)
Patterson v. Stanolind Oil & Gas Co.
Argued December 7, 1938
Decided January 3, 1939
305 U.S. 376
1. The owner-lessor of the mineral rights in a tract of land on which was a producing oil well was not deprived of property rights in violation of the Fourteenth Amendment, nor were his contractual rights impaired, by an order of the Oklahoma Corporation Commission, made after due hearing and pursuant to c. 59, Oklahoma Session Laws, 1935, whereby part of his land, with the well, was included in the same 10-acre well spacing and drilling unit with land of other owner-lessors, and whereby he was obliged, under § 4(c) of the statute, to share with them in one-eighth of the production from the well, in proportion to their respective acreages in such unit -- it being assumed, as found by the Commission, that there is a common source of supply, and that establishment of the units will tend to effect proper drainage of the oil pool, result in uniform withdrawal and greatest ultimate recovery of oil, conserve reservoir energy, and protect the relative rights of the leaseholders and royalty owners in the common source of supply. P. 305 U. S. 377.
2. Contention that regulatory provisions of c. 59, Okla.Sess.Laws, 1935, authorizing the State Corporation Commission to fix well spacing and drilling units are void for indefiniteness -- held without merit. P. 305 U. S. 379.