Ronald and Barbara Bohlen v. Anadarko E&P Onshore LLC et al., Case No. 2015-0187
Fourth District Court of Appeals (Washington County)

ISSUES:
- Are "delay rental" payments equivalent to "minimum advance royalty" payments in an oil and gas lease, and can they be construed to be the same when seeking to terminate a lease for nonpayment?
- Are "delay rental" clauses limited to the primary term of an oil and gas lease or can a lease's language alter the meaning of the term to extend the clause into the secondary term?