Ramsey Herndon LLC v. Whiteside

Plaintiff company sued for breach of contract and conversion because Defendant refused to pay Plaintiff royalties arising from an oil and gas lease. Plaintiff failed to state a cause of action for breach of contract. Instrument of assignment unambiguously transferred all of Plaintiff's interest to Defendant, so Defendant's refusal to pay Plaintiff royalties was not a breach. As nothing in the instrument reduces the general grant of "all" of Plaintiff's interest, Defendant owns the overriding royalty interest. (KARMEIER, FREEMAN, THOMAS, KILBRIDE, BURKE, and THEIS, concurring.)