EnerVest Operating, LLC v. Sebastian Mining, LLC, 676 F.3d 1144 (8th Cir. 2012)

(coal ownership and oil, gas, and other mineral rights in property were separately conveyed in different deeds; coal bed methane (CBM) gas rights in property were not specifically enunciated in any conveyance; parties moved for summary judgment on stipulated facts that included deeds to determine ownership of CBM rights; district court held CBM was conveyed to gas owners who were entitled to royalties; coal owners appealed; appellate court held coal rights were narrowly granted in language of deed but rights conveyed to gas owners were broadly granted; appellate court held that minerals with no known commercial value at time of conveyance not factually relevant when language of deeds provided clear notice of grantor's intent; argument that mineral owners would destroy coal owners' rights to coal in effort to collect CBM was unpersuasive to defeat language of conveyance; gas owners had CBM rights; district court order affirmed).