June Webinar | Multi-Fraction Deeds After Clifton v. Johnson with Corey Wehmeyer

ATX-ALTA's June 2026 Webinar

Multi-Fraction Deeds After Clifton v. Johnson:

Rebutting the Van Dyke Presumption

and the Continuing Role of the Presumed Grant Doctrine

featuring Guest Speaker
Corey Wehmeyer

Managing Shareholder
Santoyo Wehmeyer P.C.

CPLTA Credit  | CDOA Credit

In Clifton v. Johnson, the Supreme Court of Texas substantively revisited multi-fraction deed construction for the first time since Van Dyke v. Navigator Group, which established the rebuttable presumption that “1/8” in a double-fraction grant or reservation refers to the entire mineral estate and confirmed presumed grant as an independent ground for resolving title disputes. The Clifton Court held that the presumption was rebutted by the deed’s text, marking its first decision overcoming the presumption on the four corners of the instrument. This presentation examines what Clifton tells practitioners about the textual features that will and will not rebut the Van Dyke presumption, the continuing role of the presumed grant doctrine as an independent path to resolution, and the open questions that remain as cases like Hoffman v. Thomson work their way through the appellate pipeline.

Corey Wehmeyer represents energy industry participants in trials, arbitrations and disputes. Clients include operators, working interest owners, drilling contractors, oil field service companies, pipeline companies, refiners, and mining companies. He has handled matters in Texas, New Mexico and Oklahoma. He also represents clients in general real property and commercial litigation matters. As lead attorney, Corey has tried oil and gas jury trials to multi-million dollar verdict and judgment for clients, and has also secured take nothing defense verdicts. Corey is also an appellate attorney and has successfully represented energy clients in oral argument and briefing before the Supreme Court of Texas, and many intermediate courts of appeal. Corey is the Managing Shareholder of Santoyo Wehmeyer P.C. He is also Board Certified by the Texas Board of Legal Specialization in both of Civil Trial Law and Oil, Gas and Mineral Law, and is an elected member of the American Board of Trial Advocates (ABOTA).