On August 28th, Ohio's Seventh District Court of Appeals issued a decision on the 1989 version of the Ohio Dormant Mineral Act (1989 DMA). In Eisenbarth v. Ruesser, the Seventh District held:

  1. An oil and gas lease is a title transaction Savings Event;
  2. The 1989 DMA creates a fixed, rather than a rolling look-back period; and
  3. A conveyance of the executive right, without more, does not include the right to receive the bonus payment under an oil and gas lease. 

You can read the decision here.