In re Sabin Oil & Gas, United States Bankruptcy Court for the Southern District of New York, May 3, 2016; 2016 Bankr. LEXIS 1905
Sabine was permitted to reject two agreements regarding the gathering and sale of oil and gas production from its leases.
The court held that the sale of oil and gas after production is a contract for the sale of personal property and does not constitute a covenant running with the land that would prevent the debtor from rejecting the contract under Sec.365 of the Bankruptcy Code.