Advertisement On June 21, 2013, the Superior Court of Pennsylvania (the “Court”) held that a lessee does not owe a duty to a lessor to develop each and every “economically exploitable strata” under an oil as gas lease in Pennsylvania. Advertisement In early 2012, Terry L. Caldwell and Carol A. Caldwell, husband and wife (“Plaintiffs”) … Continue reading No Implied Duty to Develop Particular Strata in Pennsylvania (e.g. Marcellus Shale)