Phillips Petroleum Co. v. Curtis
182 F.2d 122, 1950 U.S. App. LEXIS 3847 (1950)
Sections
Case Podcast
Listen to an audio breakdown of Phillips Petroleum Co. v. Curtis.
Rule of Law:
The Legal Principle
This section distills the key legal rule established or applied by the court—the one-liner you'll want to remember for exams.
Facts:
- On October 4, 1946, Joe W. and Lois B. Curtis granted an 'unless' oil and gas lease to James T. Blanton.
- The lease stipulated that it would terminate if a well was not commenced by October 4, 1947, unless the lessee paid a delay rental of $40 on or before that date.
- Phillips Petroleum Company acquired the lease by assignment from Blanton on January 22, 1948.
- The Curtises subsequently sold a portion of their mineral interest, which apportioned the delay rental due to them to $11.67 for the October 4, 1948 payment.
- On September 15, 1948, a Phillips employee, believing a well on an adjacent tract held the lease, mistakenly marked the lease record as being held by production.
- Due to this internal clerical error, Phillips failed to pay or tender the $11.67 delay rental to the Curtises on or before the due date of October 4, 1948.
- Upon discovering the mistake around December 1, 1948, Phillips immediately tendered the payment with interest, but the Curtises refused to accept it.
Procedural Posture:
How It Got Here
Understand the case's journey through the courts—who sued whom, what happened at trial, and why it ended up on appeal.
Issue:
Legal Question at Stake
This section breaks down the central legal question the court had to answer, written in plain language so you can quickly grasp what's being decided.
Opinions:
Majority, Concurrences & Dissents
Read clear summaries of each judge's reasoning—the majority holding, any concurrences, and dissenting views—so you understand all perspectives.
Analysis:
Why This Case Matters
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