Picard v. Richards
In Picard v. Richards, 366 P.2d 119 (Wyo. 1961), Chief Justice Blume provided a detailed and thoughtful discussion of the use of those terms which clearly demonstrates each has a separate and distinct meaning and the interests conveyed depend on the terms employed.
Specifically, the court recognized the term royalty was used to designate an interest carved out of the mineral estate and reserved to the owner of the mineral interest for permitting another to use the property and included the right to "'receive, either in kind or its equivalent in money, a stipulated fraction of the oil and gas.'" 366 P.2d at 123.
In contrast, the court recognized, "Bonus and delay rentals, or a portion thereof, go with such a mineral estate, as shown by the foregoing cases." Id.