Chevron Oil Co. v. Howell
In Chevron Oil Co. v. Howell, 407 S.W.2d 525 (Tex. Civ. App.--Dallas 1966, writ ref'd n.r.e.), Chevron started drilling a directional well from Howell's surface estate through a severed mineral estate to reach an adjacent mineral estate.
Howell sued and the trial court granted a temporary injunction against Chevron's drilling. Id.
Because Chevron drilled without permission from Howell or the mineral estate's owner, the Dallas court affirmed the trial court's order. Id. at 528.
In that case, the surface estate owner did not give Chevron permission to drill. Cf. id. at 526.