Sam H. Bennion v. Anr Production Company

This is a case of first impression on the rights of a non-consenting mineral owner under the forced pooling provisions of the Utah Oil and Gas Conservation Act. The case raises questions regarding the drilling of increased density wells in a drilling unit already subject to a forced pooling order. The operative facts span nearly two decades, from 1971 to 1990. During that period, the Oil and Gas Conservation Act underwent several amendments and a complete repeal and reenactment. We discuss the effect of those changes on the parties rights and liabilities, and we examine constitutional and statutory challenges to certain changes in the act.