## Facts

- The Vickie Lynn oil field in Marion County, Texas was governed by Railroad Commission rules using 80-acre proration units and 660-foot lease-line setbacks; closer wells were “irregular.”
- The Manziel Estate–Mathis lease had a well drilled closer than the standard spacing (about 330 feet from the boundary) and was the only tract not following the general spacing pattern.
- Reservoir pressure in the solution-gas drive field declined substantially, making remaining oil difficult to produce by primary recovery.
- To prevent waste and protect correlative rights through secondary recovery, the Commission issued an order (Dec. 12, 1960) allowing Whelan Brothers to drill and inject water in the Eldridge No. 11 well at an irregular location about 206 feet from the Manziel boundary.
- The Manziels sued to set aside the order and to enjoin both its enforcement and the Whelans’ water injection, alleging waste, confiscation, lack of necessity to protect Whelans’ rights, violation of spacing rules, and subsurface trespass from migrating injected fluids.
- The district court cancelled the Commission’s order and enjoined the injection; the Commission and Whelans appealed directly to the Texas Supreme Court.

## Issues

1. Whether substantial evidence supported the Commission’s exception allowing water injection from an irregularly located well to prevent waste and protect correlative rights.
2. Whether Commission-authorized water injection that causes subsurface migration across lease lines constitutes an actionable trespass that can be enjoined.
3. Whether the order unlawfully confiscated the Manziels’ property or otherwise failed to protect correlative rights and due process.

## Decision

- The Texas Supreme Court reversed the district court and reinstated the Commission’s order.
- The Court held the order was supported by substantial evidence and within the Commission’s conservation authority.
- The Court rejected trespass-based injunctive relief for subsurface fluid migration resulting from a valid, authorized secondary recovery project.
- The Court found no unconstitutional confiscation or deprivation of property without due process.

## Legal Principles

- Courts review Railroad Commission conservation orders under the substantial-evidence standard and do not substitute their judgment for the agency’s on technical reservoir matters.
- The Commission may grant spacing exceptions for secondary recovery when reasonably necessary to prevent waste and protect correlative rights.
- When a secondary recovery project is lawfully authorized, cross-boundary movement of injected fluids within a common reservoir is not treated as a common-law trespass for purposes of enjoining the operation.
- Regulatory adjustments of competing interests in a common reservoir do not constitute unconstitutional confiscation if the Commission acts within statutory authority and provides notice and hearing.

## Conclusion

The court upheld a Commission order allowing an irregularly located water-injection well for a waterflood, ruling that substantial evidence supported the conservation decision and that subsurface migration of injected fluids across lease lines, when authorized, does not give neighboring owners a trespass-based right to stop the project.


Railroad Comm'n of Tex. v. Manziel, 361 S.W.2d 560 (Tex. 1962)