The Duhig Rule is back, this time in Echols Minerals LLC, et al v. Green et al.
![](https://www.energyandthelaw.com/wp-content/uploads/sites/320/2023/11/promise-656x437.jpg)
Framing the discussion, Duhig v. Peavy Moore Lumber Company and Trial v. Dragon
In Duhig the grantor in a general warranty deed warranted title and reserved half of the minerals. The deed did not mention that a