• PRO
  • Events
  • About Blog Popular
  • Login
  • Register
  • PRO
  • Resources
    • Latest updates
    • Q&A
    • In-depth
    • In-house view
    • Practical resources
    • FromCounsel New
    • Commentary
  • Research tools
    • Global research hub
    • Lexy
    • Primary sources
    • Scanner
    • Research reports
  • Resources
  • Research tools
  • Learn
    • All
    • Masterclasses
    • Videos
  • Learn
  • Experts
    • Find experts
    • Influencers
    • Client Choice New
    • Firms
    • About
    Introducing Instruct Counsel
    The next generation search tool for finding the right lawyer for you.
  • Experts
  • My newsfeed
  • Events
  • About
  • Blog
  • Popular
  • Find experts
  • Influencers
  • Client Choice New
  • Firms
  • About
Introducing Instruct Counsel
The next generation search tool for finding the right lawyer for you.
  • Compare
  • Topics
  • Interviews
  • Guides

Analytics

Review your content's performance and reach.

  • Analytics dashboard
  • Top articles
  • Top authors
  • Who's reading?

Content Development

Become your target audience’s go-to resource for today’s hottest topics.

  • Trending Topics
  • Discover Content
  • Horizons
  • Ideation

Client Intelligence

Understand your clients’ strategies and the most pressing issues they are facing.

  • Track Sectors
  • Track Clients
  • Mandates
  • Discover Companies
  • Reports Centre

Competitor Intelligence

Keep a step ahead of your key competitors and benchmark against them.

  • Benchmarking
  • Competitor Mandates
Home

Back Forward
  • Save & file
  • View original
  • Forward
  • Share
    • Facebook
    • Twitter
    • Linked In
  • Follow
    Please login to follow content.
  • Like
  • Instruct

add to folder:

  • My saved (default)
  • Read later
Folders shared with you

Register now for your free, tailored, daily legal newsfeed service.

Questions? Please contact [email protected]

Register

Ohio oil & gas lease disputes

Benesch Friedlander Coplan & Aronoff LLP

To view this article you need a PDF viewer such as Adobe Reader. Download Adobe Acrobat Reader

If you can't read this PDF, you can view its text here. Go back to the PDF .

USA February 28 2014

I. General Provisions – “Mineral Rights”

A. Under Ohio law, the term “mineral” generally includes oil and gas unless the language in the granting instruments suggests the parties intended otherwise. Kelly v. Ohio Oil Co., 57 Ohio St. 317 (1897).

B. Ohio has been producing oil and natural gas since the late 1800’s. There is an established body of case law that tends to support production and exploitation of mineral interests for the benefit of the landowner.

C. “Rule of Capture” generally encourages oil and gas

development. Permits landowner to develop oil and gas

production on landowner’s property irrespective of impact on

adjoining property.

D. “Rule of Capture” is limited, however, by the “Doctrine of

Correlative Rights.” A landowner who exercises the right

to produce oil and gas also has a duty to exercise that

right without negligence or waste. R.C. 1509.01(l) defines

“correlative rights” as the reasonable opportunity to recover

and receive oil and gas in and under the person’s tract

without having to drill unnecessary wells or incur other

unnecessary expense. R.C. 1509.01(H) defines “waste” to

include locating, drilling, equipping, operating or producing

an oil or gas well in a manner that reduces the quantity of

oil or gas ultimately recoverable under prudent and proper

operations from the pool or that causes or tends to cause

unnecessary or excessive surface loss or destruction of oil

or gas.

E. Correlative Rights addressed in Chapter 1509, Ohio Revised

Code:

• R.C. 1509.20 requires well owners to use every

reasonable precaution to stop and prevent waste of oil or

gas. Limits “flare off” of natural gas.

• R.C. 1509.06 establishes a limited term for a drilling

permit.

• R.C. 1509.021 addresses minimum separation for

surface location of wells.

• R.C. 1509.24-27 establishes minimum acreage for

drilling units, voluntary pooling agreements, mandatory

pooling orders and unitization of pool.

II. The “Held By Production” Doctrine

A. The “Habendum Clause” – Extending the Oil and Gas Lease

1. “Held By Production” is a general concept not a legal

principle. The focus for the legal inquiry is on terms of

the lease that may operate to extend the lease beyond

the original term (the “primary term”) to an extended

term (the “secondary term”). The later is referred to as an

“habendum clause” and may be triggered by continuing

production, operations or other events as defined in the

lease.

2. There are three seminal decisions of the Ohio Supreme

Court over the years that have impacted Ohio Oil and Gas

Law:

• Harris v. Ohio Oil Co., 57 Ohio St. 118 (1897). Held:

The rights and remedies of parties to an oil and gas

lease are determined by the terms of the written

instrument. Each lease is a contract that must be

applied in accordance with its terms. The parties are

bound by the production requirements of the lease.

(“Use it or lose it”).

• Beer v. Griffith, 161 Ohio St. 2nd 119 (1980). Held:

There is an implied covenant to “reasonably develop”

all tracts subject to an oil and gas lease and if certain

separable tracts are not developed, the lease may be

terminated as to those undeveloped tracts.

• Ionno v. Glen Gerry Corp., 2 Ohio St. 3d 131 (1983).

Held: Absent express exclusion, there is an implied

covenant in every oil and gas lease to “reasonably

develop the land.”

Ohio Oil & Gas Lease Disputes

February 2014

PUBLIC FINANCE Client Bulletin

Ohio Oil & Gas

DISPUTES

MY BENESCH MY TEAM

Cleveland • Columbus • Indianapolis • Philadelphia • Shanghai • White Plains • Wilmington

www.beneschlaw.com

3. Lease Terms May Vary

• Older Version – The term of the lease is . . . for five

(5) years and so much longer thereafter as oil, gas or

their constituents are produced in paying quantities

thereon.”

• Primary term is five (5) years.

• Extension or secondary term is dependent on

(continuous) production in “paying quantities.” The

unanswered question is: what are “paying quantities”?

• Modern Leases – With horizontal drilling and more

complicated operational requirements to permit,

drill, and complete horizontal wells for production,

the emphasis on the secondary term is now on

“operations” rather than “production” and includes

such acts as site preparation, exploration, pooling

and permitting activities. See Henry v. Chesapeake

Appalachia LLC, Sixth Circuit, Case No. 12-4090,

January 14, 2014 (Chesapeake’s filing a Declaration

and Notice of Pooled Unit (DPU) including plaintiffs

land was a defined “operation” extending the lease to

the secondary term.

4. Assignment of Lease

• Oil and gas leases typically are decades old and have

been conveyed, assigned, or transferred in a variety

of ways over the years. Oil and gas lease rights may

be assigned, devised, licensed, partitioned, pledged or

released and may be conveyed by various instruments

including Sheriff’s deed, bankruptcy or receivership

actions, probate, judgment entry or other means of

assignment.

• Per R.C. 5301.09, leases, licenses and assignments

of natural gas and oil rights must be filed for record

without delay. No such lease or license is valid until

it is filed for record except as between the parties,

unless the person claiming thereunder is in actual and

open possession.

• An oil and gas review will typically require a

comprehensive title search to determine the title

chain, reservation of mineral interests and recording

of oil and gas leases. A good title search will include

a “working interest” analysis to address whether there

has been continuous production or operation of a

given well or wells. The “working interest” review will

likely focus on public ODNR well logs and production

reports.

• The “assignment” creates no greater rights than

provided in the “root” lease. The assignees’ rights and

remedies are determined by the terms of the written

instrument, the conduct of predecessor – in-interest

and applicable Ohio law. Harris v. Ohio Oil Co., 57

Ohio St. 118 (1897).

B. Express Lease Terms Control – Failure of required

production required by the express lease terms results in

automatic termination.

1. Is an oil and gas lease a fee simple determinable

which automatically reverts to the lessor upon failure

of performance or a fee simple subject to a condition

subsequent which may give rise to a claim for

termination?

2. Under Ohio law, a leasehold in an oil and gas lease

terminates automatically without any requirement of

notice or judicial ascertainment in the event of failure

of production at or after the end of the primary term.

Hanna v. Shorts, 163 Ohio St. 44 (1955) (Since no oil or

gas was produced for sale during the term of the lease,

the lease automatically expired by its terms); American

Energy Services, Inc. v. Lekan, 75 Ohio App.3d 205 (5th

Dist. 1992) (If after the expiration of the primary term

of an oil and gas lease the conditions of the secondary

term are not continuing to be met, the lease terminates

by the express terms of the contract and by operation of

law and revests the leased estate in the lessor.); Wagner

v. Smith, 8 Ohio App.3d 90 (4th Dist. 1984) citing Brown

v. Fowler, 65 Ohio St. 507 (1902) (Since the term of the

lease, after its initial fixed term or terms, was dependent

upon continued production of oil or gas in paying

quantities, the issue is not one of forfeiture as upon a

condition or covenant, but whether the lease expired by

failure to produce gas or oil in paying quantities); Tisdale

v. Walla, 1994 WL 738744 at *4 (11th Dist. 1994)

(The lease terminated automatically for lack of required

production without the necessity of notice, demand or

judicial ascertainment.); Moore v. Adams, 2008 WL

4907590 (5th Dist. 2008) citing North Star Oil & Gas Co.

v. Blubaugh, 1981 WL 6434 (5th Dist. 1981) (Lessee’s

failure to operate a well or pay shut-in royalties for more

than six (6) years caused the lease to terminate by its

terms); Kramer v. PAC Drilling Oil & Gas LLC, 2011 WL

6917588 at *3 (9th Dist. 2011) (An oil and gas lease is a

fee simple determinable.).

3. Evidence of non-qualifying production can include ODNR

well logs and production reports, tax reports, royalties

paid, the duration of non-production and the reasons.

ODNR records may be incomplete. Production reporting

may be suspect and identification of wells and well

coordinates may have errors.

February 2014 Ohio Oil & Gas DISPUTES

4. Courts generally consider the circumstances of the

non-production: (1) the duration of non-production; (2)

cause of the cessation; and (3) the lessee’s diligence in

restoring production. Wagner v. Smith, 8 Ohio App. 3d 90

(4th Dist. 1984).

5. If the landowner currently accepts royalty payments

under the lease, the lease may be held to be ratified.

Litton v. Geisler, 76 N.E. 2d 741, 743 (4th Dist. 1945).

Contra, Bonner Farms Ltd. v. Fritz, 355 F. App’x 10,

16 (6th Cir. 2009). (Landowner is entitled to royalty

payments and acceptance is not a ratification of nonperformance

of the lease.).

6. The definition of “paying quantities” requires some

commercial production generally at a profit over costs

of operation. Production for domestic use only is not

“commercial production” in “paying quantities.” Tisdale v.

Walla, 1994 WL 738744 (11th Dist. 1994).

7. The doctrine of apportionment of rents does not dispose

of the rights of separate owners of separate tracts

subject to a lease. Northwestern Ohio Natural Gas Co.

v. Ullery, 68 Ohio St. 259 (1903). Quite to the contrary,

since no royalties attributable to production from any

well have been paid, it follows that the lease has been

forfeited and abandoned for lack of production. See

Northwestern Ohio Natural Gas Co. v. Davis, 3 Ohio

Dec. 282 (Cir. Ct. 1895) aff’d 59 Ohio St. 591 (1898);

Anderson v. Chief Drilling, Inc. 1983 WL 6351 (5th

Dist. 1983); Beer v. Griffith, 1979 WL 210970 (5th Dist.

1974), aff’d 61 Ohio St.2d 119 (1980).

C. Production must apply to all tracts. “Held by production”

may be limited to a producing tract.

1. Applies to Producing Tract

Where only a portion of the entire leasehold property

subject to an oil and gas lease is actually developed for

oil and gas production, the lease is forfeited for nonproduction

as respects the portions undeveloped. See

Northwestern Ohio Natural Gas Co. v. Davis, supra (Tract

purchased by a subsequent owner is held to be treated

as a separate tract under an oil and gas lease and the

lease expires on its own terms as to that separate tract

where gas was no longer found in paying quantities on

that tract.); Anderson v. Chief Drilling, Inc., supra (Where

there was no production on two tracts of land subject to

an oil and gas lease, the lease is cancelled by its terms

as to those tracts notwithstanding production from a

third tract.); Beer v. Griffith, supra (With respect to wells

requiring future efforts to be productive and with respect

to all unexploited acreage, forfeiture of lessee’s interest is

warranted in order to assure the development of the land

and the protection of the lessor’s interest.); Coffenberry v.

Sun Oil, 68 Ohio St. 488 (1903).

In Anderson v. Chief Drilling, there were originally a 160,

60 and 108 acre tract that comprised the leasehold. The

60 and 108 acre tract were subsequently transferred to

one individual while another owned the 160 acre tract.

Any production on the 160 acre tract did not operate to

bind the balance of the tracts. In Beer v. Griffith, the court

ordered forfeiture of the lease as to the portions of the

leased property not developed.

2. May be limited to the operational “footprint” of the well.

Zimmerman v. Mormack Industries, Inc. 1989 WL 50677

(9th Dist. 1989) (Court ordered forfeiture of all 322 acre

lease parcel for non-production except for the 20 acres

upon which one production well was sited to comply with

then current ODNR well-spacing requirements). Brannon

v. King, 1985 WL 6153 (9th Dist. 1985) (Court ordered

forfeiture of the majority of the leased property for nonproduction

except for the one (1) acre site upon which

a producing well was located,); Lake v. Ohio Fuel Gas

Co., 2 Ohio App.2d 227 (5th Dist. 1965) (Lessor waived

a claim of forfeiture of lease premises by accepting

royalties but not as to the portion of the property for

which there was no production.) citing Sauder v. Mid-

Continent Petroleum Corp., 292 U.S. 272, 54 S.Ct. 671,

78 L.Ed. 1255 (1934) (The production of oil on a small

portion of the leased tract cannot justify the lessee’s

holding the balance indefinitely and depriving the lessor,

not only of the expected royalty from production pursuant

to the lease, but of the privilege of making some other

arrangement for availing himself of the mineral content of

the land.).

D. No Requirement Of Advance Notice

There is no advance notice or demand requirement to

trigger forfeiture for non-production. See Harris v. Ohio Oil

Co., 57 Ohio St. 118 (1897) (While a demand was made,

the court did not hold notice and demand was required.);

Zimmerman v. Mormack Industries, Inc., 1989 WL 50677

(9th Dist. 1989) (While notices and demands were made,

the court did not hold that these were required for a claim

of forfeiture.); Brannon v. King, 1985 WL 6153 (9th Dist.

1985) (The court actually held notice and demand was of no

consequence because no notice or demand is required as a

condition to a forfeiture action.). See also Hanna v. Shorts,

supra, Anderson Energy Service, Inc. v. Lekan, supra and

other cases cited above for the proposition that an oil and

gas lease terminates automatically without any requirement

of notice or judicial ascertainment in the event of failure of

production at or after the end of the primary term.

February 2014 Ohio Oil & Gas DISPUTES

February 2014 Ohio Oil & Gas DISPUTES

E. “Implied Covenants”

1. In the absence of an express exclusion, there is

an implied covenant in every oil and gas lease to

“reasonably develop the land” for mineral production. The

purpose of this implied covenant is to ensure reasonable

and timely development of mineral interests and the

protection of the lessor’s interest. Ionno v. Glen-Gerry

Corp., 2 Ohio St. 3d 131 (1983); Beer v. Griffith, supra.

2. Ohio cases have addressed other “implied covenants”

including:

• The covenant of reasonable development and

additional exploration;

• The covenant to market the product;

• The covenant to conduct all operations that affect the

lessor’s royalty interest with reasonable care and due

diligence.

See, American Energy Services, Inc. v. Lekan, 598 N.E. 2d 1315

(1992) 212 citing Williams & Meyers, Oil and Gas Law (1991);

Moore v. Adams, 2008 WL 4907590 (5th Dist. Nov. 17, 2008).

3. Implied covenants can be disclaimed. Holonko v. H.D.

Collins, 1988 WL 70900 (7th Dist. June 29, 1988);

Bushman v. MFC Drilling Inc., 1955 WL 434409 (9th

Dist. July 19, 1995).

4. Forfeiture is an equitable remedy which will only apply

where damages are inadequate. Where an implied

covenant is breached, forfeiture of the lease may apply

but only where damages are not an adequate remedy.

Ionno v. Glen-Gerry Corp., supra at 134-135.

5. If a lease continues under “held by production”, damages

may still apply to compensate for non-performance.

III. Mandatory Pooling Orders

A. If the landowner declines to grant a lease, the developer or

other landowners can still pursue alternative unitization or

mandatory pooling options addressed in Chapter 1509, Ohio

Revised Code. These alternatives can force inclusion of land

within a drilling unit subject to ratable compensation.

B. Relevant provisions of Chapter 1509, Ohio Revised Code

are:

R.C. 1509.26 – Agreements to Pool Tracts to Form Drilling Unit

Owners of adjoining tracts may agree to pool the tracts to form

a drilling unit that forms to minimum acreage and distance

requirements. Agreement shall be in writing and submitted

to the division with the permit application required by R.C.

1509.05.

R.C. 1509.27 – Mandatory Pooling Orders

If a tract of land is of insufficient size or shape to meet the

requirements for a drilling unit and owner of tract who is also

owner of mineral interest has been unable to form a drilling

unit under agreement under R.C. 1509.26, owner may make

application for a mandatory pooling order.

Application shall include information required by Chief and

shall be accompanied by an application for a permit under R.C.

1509.05. Chief shall notify owners of land within the area to

be included in drilling unit and provide for a hearing. Chief may

issue a mandatory pooling order which would include:

• Description of boundaries of drilling unit

• Proposed production site

• Description of each tract of land pooled

• Allocation on a surface acreage basis or pro rate portion

of production to each tract owner. May vary as to specific

geology circumstances

• Specify the basis for sharing expenses if owner elects to

participate in drilling

• Designate the person to whom the permit shall issue

Statute also addresses rights and duties of a non-participating

owner.

R.C. 1509.28 – Order Providing for Unit Operation

Chief, upon own motion or upon application by the owners

of 65% of the land overlying the pool, shall hold a hearing to

consider the need for operation of the pool as a unit. Chief may

issue an order providing for unit operation if such operation is

reasonably necessary to substantially increase ultimate recovery

of oil and gas. Statute further provides for requirements of an

order. Order conditioned upon approval of 65% of the owners of

the plan for unit operation.

R.C. 1509.29 – Order Establishing Exception Tract

Upon application by an owner of a tract for which a drilling

permit may not be issued and the owner is unable to enter into

a voluntary pooling agreement or a mandatory pooling order,

Chief may issue a permit and order establishing the tract as an

exception tract. Statute further provides additional conditions for

the exception tract.

IV. Ohio’s Forfeiture Statute

R.C. 5301.332 provides a mechanism for a lessor to have a

lease cancelled of record where there has been no sufficient

production under the terms of the lease.

R.C. 5301.332 provides that whenever leases concerning lands

upon which there are no producing or drilling oil and gas wells

become forfeited, the lessor may file for record an affidavit of

forfeiture.

February 2014 Ohio Oil & Gas DISPUTES

Lessor shall give notice by certified mail and, upon failure,

by publication, upon lessee, successors or assigns. Affidavit

shall identify lease, state the cause of forfeiture and shall state

lessor’s intent to file an affidavit of forfeiture.

After 30 days and not more than 60 days after notice, lessor

may file affidavit of forfeiture identifying the lease, stating the

cause of forfeiture, confirming that there are no producing or

drilling wells and lease has been forfeited.

If lessee, successors or assigns contest forfeiture, lessor or

assigns shall notify the lessor filing the affidavit of forfeiture

within 60 days after notice. Lessee or assigns shall file for

record an affidavit denying the lease has been forfeited.

If lessee or assigns do not contest forfeiture, county recorder

shall note the lease cancellation of record.

V. Ohio’s Dormant Minerals Act

R.C. 5301.56 provides a surface owner with the opportunity

to clear title to previously severed mineral interests if those

interests have not been “used” during a 20 year look-back

period. The 1989 version of the statute is a “use it or lose

it” statute. If rights have not been exercised within a 20 year

look-back time period, rights are automatically vested in

surface owner. The 2006 version of R.C. 5301.56, which was

substantially amended, provides that the surface owner must

follow a notice and multi-step process to invalidate an interest.

The “savings” exceptions are:

a. A “title transaction” filed or recorded in the county recorder’s

office;

b. Actual production of oil or gas by the mineral interest owner;

c. Underground storage operations on the property;

d. Issuance of a drilling or mining permit to the mineral interest

owner;

e. The recording of an affidavit to preserve the mineral interest;

or

f. The creation of a separate tax parcel for the severed mineral

interest.

The owner must serve notice by certified mail to each holder

or each holder’s successors or assignees, at the last known

address of each, of the owner’s intent to declare the mineral

interest abandoned. If certified mail notice is not possible, the

surface owner must publish notice at least once in a newspaper

of general circulation n each county in which the land is

located.

The owner may then file in the county recorder’s office an

affidavit of abandonment at least 30, but not later than 60, days

after the date on which the notice was served or published.

The affidavit must contain: (i) a statement that the person filing

the affidavit is the surface owner; (ii) the volume and page

number of the recorded instrument of the mineral interest; (iii)

a statement that the mineral interest has been abandoned; (iv)

the facts constituting the abandonment; and (v) a statement

that notice was served on each mineral interest holder or their

successors or assignees.

There are significant issues in the operation of R.C. 5301.56.

These issues include:

1. Which version of statute applies?

Wendt v. Dickerson, Tuscarawas Cty. C.P., Case No.

2012CV0135 (February 21, 2013). Held: 1989 version

applies since 2006 amendment cannot affect rights

“previously acquired” under 1989 law.

2. Is the statute constitutional?

Tribett v. Shepherd, Belmont Cty. C.P. Ct., Case No. 12-CV-

180 (July 22, 2013). 1989 version is constitutional relying

on Texaco v. Short, 454 U.S. 516.

3. If 1989 version applies, what is the 20 year look-back

period? Various interpretations – Fixed period March 22,

1969 through March 22, 1989 or March 22, 1972 through

March 22, 1992 or 20 years prior to date of inquiry.

4. What “title transactions” are covered?

– Oil and gas lease covered – Bender v. Morgan,

Columbiana Cty. C.P., Case No. 2012-CV-378 (Mar. 20,

2013).

– Transfer of surface property that referenced the severed

mineral interest. Croskey v. Dodd, Harrison Cty., C.P.,

Case No. CVH-2011-0019 (Oct. 29, 2012).

VI. Recent Cases

Chesapeake Exploration, LLC v. Oil and Gas Commission,

Slip Op. No. 2013-Ohio-224 (January 30, 2013) – Writ of

prohibition granted prohibiting Ohio Oil and Gas Commission

from exercising jurisdiction in an appeal from issuance of a

drilling permit. A leaseholder appealed. Held: Pursuant to R.C.

1509.06(F), issuance of a permit shall not be considered an

order of chief. No appeal rights to Oil & Gas Commission.

Wendt v. Dickerson, Tuscarawas Cty. C.P. Case No. 2012-CV-

02-0135 (February 21, 2013). Plaintiffs filed complaint for

declaration regarding their ownership of mineral rights and to

quiet title. Held: 1989 version of R.C. 5301.56 applies. Under

that version, severed mineral interests were automatically

abandoned.

Mong v. Kovach Holdings LLC, 2013-Ohio 882 (11th Dist.

Trumbull Cty. 2013). Held: Reformation of an instrument is not

justified where contract of sale indicates the reservation of oil

and gas rights but the deed omits such reservation.

February 2014 Ohio Oil & Gas DISPUTES

Cleveland • Columbus • Indianapolis • Philadelphia • Shanghai • White Plains • Wilmington

www.beneschlaw.com

Bilbarin Farm, Inc. v. Bakerwell, Inc., 2013 – Ohio – 2487 (5th

Dist. Knox, June 12, 2013). Held: Oil and Gas lease expressly

disclaimed any implied covenant to reasonably develop the

property.

Henry v. Chesapeake Appalachia, LLC, Sixth Circuit, January

14, 2014, Case No. 12-4090. Lease provided for a five-year

term through October 17, 2011 to be extended on occurrence

of various events including conduct of “operations” on the

leaseheld or on lands pooled, unilized or combined with all or

a portion of the leasehold, with no cessation greater than 180

consecutive days, provided such operation results in a well

capable of producing oil and/or gas. The term” operations”

included bona fide efforts to prepare the surface, drilling,

testing, completing, any acts in search of or in an endeavor to

obtain, maintain or increase production and any acts similar or

incident to the foregoing. Held: Chesapeake filing a Declaration

and Notice of Pooled Unit (DPU) including the subject property

was an “operation” extending the lease.

As a reminder, this Advisory is being sent to draw your attention to issues

and is not to replace legal counseling.

 

 

 

Benesch Friedlander Coplan & Aronoff LLP - Tamar Gontovnik, David Mansbery, Jr., Kevin D. Margolis, Julie M. Price, Michael A. Primrose and Orla E. “Chip” Collier

Back Forward
  • Save & file
  • View original
  • Forward
  • Share
    • Facebook
    • Twitter
    • Linked In
  • Follow
    Please login to follow content.
  • Like
  • Instruct

add to folder:

  • My saved (default)
  • Read later
Folders shared with you

Filed under

  • USA
  • Ohio
  • Energy & Natural Resources
  • Litigation
  • Real Estate
  • Benesch Friedlander Coplan & Aronoff LLP

Popular articles from this firm

  1. Homeland Security Implements New Program for Employers to Hire Foreign Workers, but There’s a Catch *
  2. California and Colorado Among Jurisdictions Increasing Wage Violation Enforcement *
  3. FTC Announces Changes to HSR Thresholds and Fees *
  4. CMS Adds SNFs to “High” Screening Category, Greater Scrutiny of Change of Ownership and Provider Enrollment/Revalidation *
  5. Privacy Points 2023: California and Colorado Will Soon Require Acceptance and Adherence to Universal Opt-Out Mechanisms *

If you would like to learn how Lexology can drive your content marketing strategy forward, please email [email protected].

Powered by Lexology

Related practical resources PRO

  • How-to guide How-to guide: How to draft a confidentiality agreement (UK)
  • How-to guide How-to guide: How to manage the risk of contracting with a company in financial difficulty (UK)
  • Checklist Checklist: Reducing the risk of Coronavirus (COVID-19) - guidance for employers (UK)
View all

Related research hubs

  • USA
  • Energy & Natural Resources
  • Real Estate
Back to Top
Resources
  • Daily newsfeed
  • Commentary
  • Q&A
  • Research hubs
  • Learn
  • In-depth
  • Lexy: AI search
  • Scanner
Experts
  • Find experts
  • Legal Influencers
  • Firms
  • About Instruct Counsel
More
  • About us
  • Blog
  • Events
  • Popular
Legal
  • Terms of use
  • Cookies
  • Disclaimer
  • Privacy policy
Contact
  • Contact
  • RSS feeds
  • Submissions
 
  • Login
  • Register
  • Follow on Twitter
  • Follow on LinkedIn

© Copyright 2006 - 2023 Law Business Research

Law Business Research