LAKE CHARLES, La. - A unanimous Third Circuit Louisiana Court of Appeal panel on May 7 affirmed summary judgment against surface estate owners seeking damages from oil and natural gas operators for allegedly failing to restore the surface estate; the panel applied the subsequent purchaser doctrine and concluded that the plaintiffs lack standing to seek damages for alleged injuries before they purchased the subject land (Carlos Boone, et uxor v. ConocoPhillips Co., et al., No. 13-1106, La. App., 3rd Cir.).