Garman v. Conoco, Inc.’s Empirical Analysis
1994
Citation profile
8 federal appellate · 8 district · 38 state decisions
How this case has been cited
Cited by 59 later decisions — most recently August 2025 · most notably Heritage Resources, Inc. v. NationsBank (1997), Atlantic Richfield Company v. The Farm Credit Bank of Wichita Stanley a Mollerstuen (2000)
8 federal appellate · 8 district · 38 state decisions
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
Applies 30 U.S.C. § 226
Relies on Patterson v. Shumate · Gilmore v. Superior Oil Co. · Piney Woods Country Life School v. Shell Oil Co. · Pittman v. Larson Distributing Co. · Matzen v. Hugoton Production Co.
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 59 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[o]verriding royalty interest owners are not obligated to share in these costs.”
5 later decisions quote this exact passage · from the majority“absent an assignment provision to the contrary, overriding royalty interest owners are not obligated to bear any share of the post-production expenses ... undertaken to transform raw gas produced at the surface into a marketable product.” 886 P.2d at 661 . The Supreme Court of Colorado noted that, although an oil-and-gas lease is”
4 later decisions quote this exact passage · from the majority“Allocating these costs to the lessee is also traceable to the basic difference between cost bearing interests and royalty and overriding royalty interest owners. Normally, paying parties have the right to discuss proposed procedures and expenditures and ultimately have the right to disagree with the course of conduct selected by the operator. Under the terms of a standard operating agreement nonoperating working interest owners have the right to go "non-consent" on an operation and be subject to an agreed upon penalty. See A.A.P.L. Form 610-1989 Model Form Operating Agreement Art. VI.b.ii. This right checks an operator's unbridled ability to incur costs without full consideration of their economic effect. No such right exists for nonworking interest owners.”
3 later decisions 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.