PLEASE NOTE: Due to the upcoming Good Friday and Easter holidays, there is no report next Monday. The next report will be published on April 29, 2019.FEDERAL - JUDICIAL: Notarization; Constructive Notice; Leasing – New Mexico. On March 29, in Marathon Oil Permian, LLC, v. Ozark Royalty Co. (Case No. 1:18-cv-00548-JCH-SCY), the U.S. District Court for the District of New Mexico addressed a "dispute over a roughly 40-acre mineral estate lease which began with a notary's error in notarizing the wrong signature on a lease conveyance." The parties disputed whether New Mexico law imposes a chain of title requirement that a recorded deed can impart constructive notice to a bona fide purchaser only if it is a link in the purchaser's chain of title searchable in the records. The court noted that the "answer is that the New Mexico Supreme Court has laid down such a rule: a purchaser is charged with constructive notice 'of all recorded documents within the purchaser's chain of title.'" Here, the court dismissed the claim against a bona fide lease purchaser, noting that the prior owner attempted to record the lease with a defective notarization, which the county recorded rejected. The subsequent purchaser then acquired the lease months later but without actual or constructive notice of the prior owner's acquisition because the lease was not recorded in the chain of title. Read more.STATE - LEGISLATIVE: Employee Classification – Oklahoma. (Update to 4/8/19 Weekly Report) On April 11, HB 1095 passed the Senate. The bill passed the House in March. The legislation, sponsored by Rep. Mike Osburn (R), utilizes the IRS 20-factor test to determine whether or not an employer-employee relationship exists but would give the Oklahoma Employment Security Commission the authority to make the determination. If signed into law, the bill would take effect January 1, 2020. Read more.INDUSTRY NEWS: Chevron to purchase Anadarko in $33 billion deal. Last Friday, Chevron announced it is acquiring Anadarko in a $33 billion deal that will make Chevron the world's third largest oil and gas producer, just behind Exxon and Royal Dutch Shell. "We will now see Chevron emerging as the clear leader among all Permian players, both in terms of production growth and as a cost leader," said Per Magnus Nysveen, head of research at consultancy, Rystad Energy. The deal will include the sale of $15 to $20 billion of assets from 2020 to 2022 to reduce debt and return cash to investors. Analysts expect the acquisition to close in the second half of 2019. Read more.