the enumerated “economical mineral resources.” Colo. Sess. Laws 1907, ch. 78, § 2(1) at 168 (emphasis added). C. Treatises and Other Sources We also note that other authorities similarly support our conclusion that the term “minerals” includes oil and gas. According to a widely cited treatise on oil and gas law, a significant majority of states holds that a reservation of minerals includes oil and gas unless other language in the instrument limits the definition of minerals so as to exclude them. However, “there is very limited authority for the proposition that the term ‘minerals’ is ambiguous as to whether or not oil and gas are included or excluded and hence extrinsic evidence may be admitted to resolve the ambiguity.” 1 H. Williams & C. Meyers, Oil & Gas Law §§ 219.1 & 219.4 (1978) (<HOLDING>). See also Reeves, The Meaning of the Word
recognizing the majority rule recognizing that although there are at least four approaches to construing the term minerals in deed reservations the clear majority view is that minerals includes oil and gas holding that because the purchase price typically is not included in the deed this term of the contract of sale is not merged with the deed recognizing that although the term good cause is undefined it is at least as demanding as the excusable neglect standard holding that the majority view is that employers are not liable for theft committed by employees