Entek GRB, LLC v. Stull Ranches, LLC addressed a common dispute in the western United States—a dispute between the surface owner and the mineral owner of a severed estate. As Judge Gorsuch articulated in Entek: “When you own property in the West you don't always own everything from the surface to the center of the Earth. Someone else might own the minerals lying underground and the right to access them. Someone else still might own the right to use the water flowing through your property. All this can invite confusion—and litigation.