In EQT Production Co. v. Opatkiewicz, et al., a Pennsylvania trial court recently held that section 34.1 of the Oil and Gas Leas Act (58 Pa.C.S. s. 34.1) does not violate the Commonwealth's Constitution nor that of the United States.  That section states:  "Where an operator has the right to develop multiple contiguous leases separately, the operator may develop those leases jointly by horizontal drilling unless expressly prohibited by a lease.  In determining the royalty where multiple contiguous leases are developed, in the absence of an agreement by all affected royalty owners, the production shall be allocated to each lease in such proportion as the operator reasonably determines to be attributable to each lease."

Interesting.