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← 345 NW2D 33 - Olson v. Schwartz

Olson v. Schwartz’s Empirical Analysis

1984

Citation profile

14
cited by 14 later decisions
1
states following
December 2015
most recently cited

2 federal appellate · 2 district · 10 state decisions

How this case has been cited

Cited by 14 later decisions — most recently December 2015

2 federal appellate · 2 district · 10 state decisions

501984199020002010decided

Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.

Relationships

Relies on Sauder v. Mid-Continent Petroleum Corp. · Brewster v. Lanyon Zinc Co. · Doss Oil Royalty Co. v. Texas Company · Boatman v. Andre · Berry v. Wondra

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

  1. ““It is well settled that the lessee of an oil and gas lease has an implied obligation to the lessor to do everything that a reasonably prudent operator would do in operating, developing, and protecting the property, with due consideration being given to the interests of both the lessor and the lessee, if there is no express clause in the lease .relieving the lessee of this implied duty. Feland v. Placid Oil Co., 171 N.W.2d 829, 835 (N.D.1969). See also 38 Am.Jur.2d Gas and Oil § 127, page 601.””
    3 later decisions quote this exact passage
  2. “"... the question of whether or not there has been reasonable development of a leasehold is determined by reference to the ‘prudent operator’ standard. It is impossible to state a formula by which a court can determine whether a particular lessee has developed a particular lease in conformity with the prudent operator standard. Each case must be decided on the facts peculiar to it and the burden of proving a breach of the implied covenant is on the party asserting it.””
    3 later decisions quote this exact passage
  3. ““(1) the quantity of oil and gas capable of being produced as indicated by prior exploration and development; (2) the local market and demand therefor; (3) the extent and results of the operations, if any, on adjacent lands; (4) the character of the natural reservoir — whether such as to permit the drainage of a large area by each well; (5) the usages of the business; (6) the cost of drilling, equipment, and operation of wells; (7) the cost of transportation, storage, and the prevailing price ... (8) general market conditions as influenced by supply and demand or by regulation of production through governmental agencies ... (9) evidence of the willingness of another operator to drill on the tract in question; (10) the attitude of the lessee toward further development; and (11) the elapsed time since drilling operations' were last conducted.” [Citations omitted.]”
    2 later decisions quote this exact passage

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.