Defendants do not seek review of the trial court's factual determinations in this lease cancellation suit. Defendants seek review of the legal standards applied by the trial court, including specific standards set forth in Hall v. Galmor, 2018 OK 59, 427 P.3d 1052.
¶43 One court has explained an incomplete but useful definition for a "primary term" as the period of time stated in the lease "during which the lease may be kept alive by a lessee by virtue of drilling operations or the payment of rentals, even though there is no production in paying quantities,... [and] is also a period of time at the end of which the estate granted will terminate but which estate may be extended by some other provision, usually one for production." In Hall v. Glamor, 2018 OK 59, 427 P.3d 1052, we noted the habendum clause in an oil and gas lease defines the lease's primary term and usually extends the lease for a secondary term of indefinite duration as long as oil, gas, or other minerals are being produced. After the primary term, a lease is effective based upon a well capable of production in paying quantities such that the lease remains viable under the habendum clause, which defines the duration of the lease in relation to the production life of the well.
If the Legislature wishes to rethink its treble-damages policy, it can do so through the procedures for making new law that are mandated by our Constitution.Hall v. Galmor , 2018 OK 59, ¶ 45, 427 P.3d 1052, 1070 ("[D]etermin[ing] the meaning of [a statute] .... begins with the text of the statute and—absent unresolvable ambiguity—ends with the text."); Broadway Clinic v. Liberty Mut. Ins. Co. , 2006 OK 29, ¶ 15, 139 P.3d 873, 877 ("In the absence of ambiguity or conflict with another enactment, our task is limited to applying a statute according to the plain meaning of the words chosen by the legislature ...."). II.
¶10 This Court's "inquiry begins with the text of the statute and--absent unresolvable ambiguity--ends with the text." Hall v. Galmor , 2018 OK 59, ¶ 45, 427 P.3d 1052, 1070. Our "task is to determine the ordinary meaning of the words that the Legislature chose", because people are governed by the laws as they are written.
¶9 This Court's "inquiry begins with the text of the statute and—absent unresolvable ambiguity-ends with the text." Hall v. Galmor , 2018 OK 59, ¶ 45, 427 P.3d 1052, 1070. Our "task is to determine the ordinary meaning of the words the legislature chose", because people are governed by the laws as they are written.
Rath v. LaFon , 1967 OK 52, ¶ 4, 431 P.2d 312, 314 (quoting Hamrick v. George , 1962 OK 247, ¶ 7, 378 P.2d 324, 326 ).We thus look to the ordinary meaning of the terms that the legislature chose. Hall v. Galmor , 2018 OK 59, ¶ 45, 427 P.3d 1052, 1070. To ascertain the ordinary meaning and achieve full force and effect of each provision, we look to the text of both the provision at issue as well as related provisions in the same statute or legislative act.
As such, we begin with the text of the statute in order to ascertain the ordinary meaning of section 3636(B), so we can then determine if State Farm's actions fall within it. See Hall v. Galmor , 2018 OK 59, ¶ 45, 427 P.3d 1052, 1070. "Legislative purpose and intent may [also] be ascertained from the language in the title to a legislative enactment." Naylor v. Petuskey , 1992 OK 88, ¶ 4, 834 P.2d 439, 441.
In summary, the existence or mandatory scope of a legally cognizable cause of action may present a jurisdictional issue.Hall v. Galmor , 2018 OK 59, n. 49, 427 P.3d 1052, 1062, citing J.P. Morgan Chase Bank Nat'l Ass'n v. Eldridge , 2012 OK 24, ¶ 7, 273 P.3d 62, 65 (quoting Hendrick v. Walters , 1993 OK 162, ¶ 4, 865 P.2d 1232, 1234 ; In re Estate of Doan , 1986 OK 15, ¶ 7, 727 P.2d 574, 576 ).Hunsucker v. Fallin , 2017 OK 100, ¶3, 408 P.3d 599, 602.
Id.E.g. , Hall v. Galmor , 2018 OK 59, ¶ 12, 427 P.3d 1052, 1061 (citing Childers v. Childers , 2016 OK 95, ¶ 18, 382 P.3d 1020, 1024 ; White v. Adoption of Baby Boy D. , 2000 OK 44, ¶ 36, 10 P.3d 212, 220 ; Briggs v. Sarkeys, Inc. , 1966 OK 168, ¶ 29, 418 P.2d 620, 624 ; Hitt v. Hitt , 1953 OK 391, ¶ 0, 258 P.2d 599, 599 ). § 78(C)(5) (emphasis added).
We review issues of law de novo.Hall v. Galmor , 2018 OK 59, ¶ 12, 427 P.3d 1052. ¶13 A quiet title action is one of equitable cognizance.