Smith, et al. v. Arrington Oil & Gas, 664 F.3d 1208 (8th Cir. 2012)

(Arkansas landowners seek summary judgment against defendant for defendant’s failure to pay cash bonuses of $300 per acre in addition to royalty payments in accordance with oil and gas leases; landowners executed leases and defendant failed to pay on bank drafts because it had made determination to abandon oil and gas exploration in the county after drilling dry well; trial court granted summary judgment on finding that lease agreements were binding and only subject to defendant’s good faith approval of title and cancellation unrelated to title; appellate court affirmed; language of written oil and gas leases coupled with bank draft issued to pay cash bonus constituted enforceable contracts; mutuality of obligation present even though bank draft contained “no-liability” clause because such clause contrary to language in lease; lease agreements were accepted in accordance with approval language and renunciation of lease does not preclude enforceability).

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