In 2022, the Supreme Court in State v. Louisiana Land & Expl. Co. (L.L.&E III), a case governed by the original version of Act 312 of 2006 (La. R.S. 30:29), held on rehearing that “the plain language of Act 312 only allows recovery of excess remediation damages when expressly provided by contract.”1 In doing so, the Supreme Court reversed its prior ruling in the same case (L.L.&E I), which held that the “clear and unambiguous” language of Act 312 of 2006 expressly preserved all of a legacy plaintiff’s pre-Act private law claims, including claims for excess damages based on the implied obligations of the mineral lessee as set forth in the Civil Code.2  In its rehearing opinion in L.L.&E III, the Supreme Court affirmed its original decree in L.L.&E II.3  The legislature amended La. R.S. 30:29 in 2014 (Acts 2014, No. 400, § 1). In an area of Louisiana law now thick with conflicting precedent, it should come as no surprise that there is intense disagreement concerning the extent to which  L.L.&E III impacts the 2014 version of La. R.S. 30:29. The opposing views of plaintiffs and defendants are separately addressed in the following discussion.