Corzelius v. Harrell.’s Empirical Analysis
1944
Citation profile
6 state decisions
Relationships
Relies on Ohio Oil Company v. State of Indiana · Thompson v. Consolidated Gas Utilities Corp. · Railroad Commission of Texas v. Shell Oil Co. · Marrs v. Railroad Commission · Middlekauff v. State Banking Board
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 6 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““We think the statute is simply and clearly phrased to give effect to a public policy, and to exercise the police power in respect to matters which the courts of Texas and of the United States uniformly hold it is the right of the state by statute, to control. This right extends to preventing one person from unduly draining from under the lands of another, oil and gas lying in a common pool equally when the undue drainage is for wasteful uses, and when the rule of capture no longer applying, because of lawful statutory limitation, one of the owners, by drawing more than his due proportion of the limited share, is draining the lands of his co-owners. “We find nothing unreasonable in the statute, nothing unreasonable in the orders. For all that the statute does, all that the orders do, is to make limitation and proration effective by putting an end to an existing unreasonable drainage condition, and preventing its continuance in the future. Neither the statute nor the order operates retrospectively, either punitively or reparatively; both operate prospectively. So operating, they merely say to plaintiffs ‘you may produce from your wells of the total amount limited in a due proportion with every other well in the field. You may not produce more’.””
1 later decision quote this exact passage · from the majority““The record shows that Corzelius is producing by volume in excess of his fair share of the total net volume allowable from the field, and to that extent is creating a local net drainage, by volume, from Harrell’s holdings. Harrell, on the other hand, though withdrawing by net volume only 2 MMCF daily, is processing 35 MMCF, extracting therefrom the valuable liquids, and is already reducing (draining) the liquid content of the gas from Corzelius’ holdings. Corzelius is entited to produce his fair share of the recoverable liquids, as well as his fair share of the volume of recoverable gas. Thus each is draining from the other’s holdings, though of different elements of the total gas content.” [ 179 S.W. 2d 425 ]”
1 later decision quote this exact passage · from the majority“that injunctive relief is merely an enforcement remedy ancillary to a judgment cancelling an order of the Commission.”
1 later decision quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.