Court of Appeals of Kansas January 16, 2009, 98,859 (Lewis v. KANSAS PRODUCTION CO., INC.)

Pierron, J.:

After a bench trial, the district court terminated Kansas Production Company’s (KPC) oil and gas lease on David and Karen Lewis’ land for KPC’s breach of the implied covenant to explore and develop the lease. The court found that KPC received no demand for development before this lawsuit was filed.