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R.R. Com. of Tex. v. Manziel - 361 S.W.2d 560 (Tex. 1962)


Regardless of the other questions that may appear, as to matters within the discretion of the Texas Railroad Commission (Commission), the ultimate decision of the court, as to the validity of the Commission's orders, must turn upon the application of the substantial evidence rule. It is not the province of the court to substitute itself for the Commission in determining the wisdom and advisability of the particular order in question, but the Court will sustain the action of the Commission so long as its conclusions are reasonably supported by substantial evidence.


Plaintiff Dorothy N. Manziel and intervenors Whelan Brothers controlled adjoining portions or "units" of a particular oil and gas field; each of the parties operated wells on their units. The Whelans' well was located at an irregular spacing 206 feet south of the boundary of Manziel's unit. Defendant Railroad Commission of Texas ("Commission"), on an application for a permit filed by the Whelans, entered an order permitting the Whelans to drill and inject water in their well. Manziel filed an action against the Commission in Texas state court seeking to set aside and cancel the Commission's an order. The Whelans intervened and aligned themselves in defense of Commission's order. In her action, Manziel alleged irregularities in the Whelans' permit application and also attacked the Commission's order on the grounds that it would cause waste, that it would result in the confiscation of Manziel's property, that the permit was not necessary to protect the correlative rights of the Whelans', and that the order was in violation of the Commission's own rules. After trial, the district court entered a judgment cancelling the Commission's order, enjoining its enforcement and enjoining the Whelans from injecting water in their well. The Commission and the Whelans appealed.


Did substantial evidence support the Commission's order?




The state supreme court reversed the district court's judgment. The court observed that under Tex. Rev. Civ. Stat. Ann. art. 6008(b), the state legislature gave the Commission the authority for determining the placement of wells in order to obtain secondary recovery of oil. On judicial review of orders from the Commission, the court noted, the ultimate decision of the courts turned upon the application of the substantial evidence rule. The court held, inter alia, that substantial evidence supported the Commission's determination that the irregular placement of the Whelans' water injection well was necessary to protect their correlative rights and to prevent drainage of oil across lease lines.

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