Ingram v. Ingram’s Empirical Analysis

Citation profile

30 state decisions

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 48 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. ““We have stated in many cases that an oil and gas lease does not create any present vested estate in the nature of title to the land which it covers or to the oil and gas in place. It merely conveys a license to enter upon the land and explore for such minerals and if they are discovered to produce and sever them. We have further declared that an oil and gas leasehold interest is personal property — an incorporeal hereditament — a profit a prendre. (Connell v. Kanwa Oil Inc., 161 Kan. 649 , 170 P.2d 631 , citing many Kansas cases to that effect.) The Kansas courts, like those of other jurisdictions, have found some difficulty in fitting the interest of an oil and gas lessee into the traditional common-law classifications relating to ordinary surface interests in land. It seems to be agreed that an oil and gas leasehold interest is a property right, but there still remains wide disagreement among the various jurisdictions of this country as to whether it is real property or personal property. A number of our opinions state categorically in general language that an oil and gas lease is personal property. (Burden v. Gypsy Oil Co., 141 Kan. 147 , 40 P.2d 463 ; Connell v. Kanwa Oil Inc., supra; Wilson v. Holm, 164 Kan. 229 , 188 P.2d 899 .) In Western Natural Gas Co. v. McDonald, 202 Kan. 98 , 446 P.2d 781 , we qualify the rule by stating that the rights created by oil and gas leases covering land in Kansas constitute intangible personal property except when that classification is”

   1 later decision quote this exact passage · from the majority
   e.g. Utica National Bank & Trust Co. v. Marney

2. “We have concluded that the legislature has determined that oil and gas leasehold interests are to be treated as real property under the statutes pertaining to recording of instruments conveying or affecting real estate. We have already mentioned K.S.A. 55-210 pertaining to the enforcement of all kinds of liens and mortgages on leaseholds for oil and gas purposes. They are to be enforced and foreclosed in the same manner as may be provided by law for enforcing liens and mortgages against real estate except that after sale of the property there shall be no redemption. Furthermore in 1953 the legislature by amendment of G.S. 1949, 67-221 specifically included oil and gas leases under the statutes which govern the recording of instruments affecting real estate.”

   1 later decision quote this exact passage · from the majority
   e.g. D & F Petroleum v. Cascade Oil Co. (In Re Cascade Oil Co.)

3. “"It is obvious from this analysis of the Kansas statutes and decisions that in this state an oil and gas lease is a hybrid property interest. For some purposes an oil and gas leasehold interest is considered to be personal property and for other purposes it is treated as real property.... We have concluded that the legislature has determined that oil and gas leasehold interests are to be treated as real property under the statutes pertaining to the recording of instruments conveying or affecting real estate." (pp. 420-421.)”

   1 later decision quote this exact passage · from the majority
   e.g. 1 Kan. App. 2d 114 - Luthi v. Evans