(January 13, 2020, 10:18 AM EST) -- YOUNGSTOWN, Ohio — An Ohio appellate panel on Dec. 9 affirmed a lower court ruling and held that a landowner’s claim for breach of contract regarding a hydraulic fracturing lease was properly dismissed because the implied covenant of reasonable development had not been violated (Thomas J. Pavsek v. Will Wade, No. 18 MO 0024, Ohio App., 7th Dist., Monroe Co., 2019 Ohio App. 5330)....