“The issue we decide in [ConocoPhillips Co. v. Ramirez] is whether a devise of ‘all . . . right, title and interest in and to Ranch “Las Piedras”‘ refers only to a surface estate by that name as understood by the testatrix and beneficiaries at the time the will was made or also includes the mineral estate. We conclude that only the surface estate was devised,” noting that the term “Las Piedras” is in quotes and the relevant conveyances show that the term was understood to have a distinct and particular meaning. No. 17-0822 (Tex. Jan. 24, 2020).

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