On December 2, 2025, the Texas Supreme Court issued its opinion in Clifton v. Johnson, No. 23-067. This is the first Supreme Court case on fixed vs. floating since its decision Van Dyke v. The Navigator Group, 668 S.W.3d 363 (Tex. 2023), its effort to clarify how double-fraction conveyances and reservations should be construed.
The reservation construed in Van Dyke was a mineral reservation:
It is understood and agreed that one-half of one-eighth of all minerals and mineral rights in said land are reserved in grantors … and are not conveyed herein.