In Armstrong v. Chesapeake Exploration, L.L.C. (Aug. 14, 2015), Ohio’s Fifth District Court of Appeals dismissed a suit by landowners seeking cancellation of an oil and gas lease for non-payment of royalties. The court found that the “[t]he oil and gas lease in this case does not contain an express provision empowering the lessor or royalty owner to declare a forfeiture thereof for the nonpayment of oil and gas royalties from production” and “[a]bsent specific language in the lease, nonpayment of royalties is not grounds for cancellation of an oil and gas lease.”

Read the decision here.