In Hooks v. Samson Lone Star, Limited Partnership, 457 S.W.3d 52, 65-66 (Tex. 2015), the similarly situated group of plaintiffs asserted that Samson owed them royalties based on the production from the Black-Stone-lease well.
The stakeholders in the Joyce DuJay Unit in Hooks were aware that Samson had amended the Black Stone Unit.
After the unit's amendment, the stakeholders in Hooks regularly accepted royalties on gas and condensate production that occurred from the Joyce DuJay Unit's pool. Id.
The Texas Supreme Court held that the stakeholders in Hooks could not claim they were due additional royalties based on the production from the Black-Stone-lease well which was no longer within the amended unit's boundaries because by their acts, they had ratified the amendment to the Black Stone Unit. Id. at 66.
Under these circumstances, the Supreme Court rendered judgment in Samson's favor based on the conclusive evidence before it of the stakeholders' acts.