Wronski v. Sun Oil Company

89 Mich.App. 11, 279 N.W.2d 564 (1979)

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Nature of the Case

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Facts

Wronski and others (P) owned 200 acres of land and their attendant mineral rights. This land, as well as some adjoining land, was subject to a uniform well spacing pattern imposed by the state Department of Natural Resources. The stated purpose of the well spacing pattern was to 'prevent waste, protect correlative rights and provide for orderly development of the pool.' Pumping from the wells was limited to 75 barrels of oil per day per well. Sun Oil (D) leased some of the property subject to the well spacing pattern and placed wells on it in accordance with the pattern. However, D began pumping more oil than was permitted, ultimately overproducing more than 180,000 barrels. P sued for an accounting, or in the alternative, compensatory and exemplary damages. The trial court found that D had illegally overproduced 150,000 barrels of oil, 50,000 of which came from P's property. The court found for P, holding D liable on a theory of conversion.