The principal issue is whether an executive mineral-rights holder, obligated to exercise “utmost good faith” to protect a non-participating royalty owner, must negotiate a market-rate royalty from leases when deeds limited future leases to a specific minimum royalty share. The question turns on the scope of the implied fiduciary-like duty the executive holder owes non-participating owners and how the deed restrictions in this case may alter that. Bradshaw, a non-participating royalty owner, sued for a greater share of royalties than Steadfast Financial, the executive rights-holder, got in leases it executed. Bradshaw inherited her royalty interests from her parents under deeds that required any future leases to pay royalties not less than one-eighth of the mineral production. As the non-participating interest-holder, she would get half of that, or one-16th. But she claims Steadfast Financial owes her twice that – one-eighth of production proceeds – because Steadfast should have sold leases at the going rate for the county. The trial court granted summary judgment for Steadfast, ruling that it did not owe Bradshaw a duty to pay her more than the minimum royalty. The court of appeals reversed.