Advanced Micromagnetics, Inc. v. Torch Energy Advisors, Inc. Torch E&P Company Rockport Resources Capital Corp. And NM Back Nine Exploration Partners, LLC

Court of Appeals of Texas·Decided October 13, 2011·No. 01-09-00138-CV·Published

Opinion

Opinion issued October 13, 2011.

In The

Court of Appeals

For The

First District of Texas

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NO. 01-09-00138-CV

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Advanced Micromagnetics, Inc., Appellant

V.

Torch Energy Advisors, Inc., Torch E&P Company, Rockport Resources Capital Corporation, and NM Back Nine Exploration Partners, LLC, Appellees

On Appeal from the 113th District Court

Harris County, Texas

Trial Court Case No. 2007-34064

MEMORANDUM OPINION

Advanced Micromagnetics, Inc. (“AMI”), appeals from a summary judgment in favor of Torch Energy Advisors, Inc., Torch E&P Co., Rockport Resources Capital Corp., and NM Back Nine Exploration Partners, LLC (collectively, “Torch” or the “Torch Defendants”).  We reverse and remand for further proceedings consistent with this opinion.

Background

AMI is a consulting company that uses proprietary geophysical technology to analyze and interpret high frequency elements of high resolution, low altitude micromagnetic data for its oil and gas exploration clients.  According to AMI, its technology reduces exploration costs and allows clients to focus upon prospects with increased success rates and reduced exploration costs.  The Torch Defendants are affiliated companies that lease, drill for, complete, produce and sell oil and natural gas in the southwestern region of the United States, including New Mexico.

In early 2005, Torch’s representative, John James Lendrum III,[1] contacted AMI President David Greenlee regarding potential oil and gas reserves in New Mexico.  At the time, Greenlee was both owner and officer of AMI, along with James Wolleben and Carl McCutcheon. 

Greenlee met Lendrum, in early March 2005, to discuss the New Mexico prospect and thereafter sent multiple communications on AMI’s letterhead to Lendrum discussing and analyzing data from an aeromagnetic survey of the New Mexico prospect provided by Lendrum.  Specifically, Greenlee sent a letter noting that AMI “should be able to significantly add to this exploration play by facilitating the ability to prioritize the magnetic structural anomalies defined by [the other] study” and thanked Lendrum for “remembering AMI.” 

The record reflects that, the following month, Greenlee submitted a proposal to Lendrum, on his personal letterhead, to process and analyze the aeromagnetic data.  Torch contends that when it asked about the change, Greenlee responded that he had the right to provide the requested analysis in his personal capacity.  The record reflects that Torch apparently agreed to hire Greenlee to provide his data analysis services and Greenlee and Torch began to negotiate the terms of an independent vendor/contractor’s agreement.  Although early drafts of the agreement named Greenlee as the vendor/contractor, at Greenlee’s request, this was later changed to Telsus Exploration, Inc.  The final agreement executed on May 26, 2005, between Torch and Telsus is referred to as the “Torch Energy Contract,”[2] pursuant to which, upon completion of the contract, Telsus received $50,000, plus an overriding royalty of 0.5% on any prospect defined and located by Telsus pursuant to the contract.  AMI claims that Torch’s use of AMI’s proprietary information and intellectual property caused Torch to identify thirty-three defined micromagnecitc prospects, from which Torch had profited already and would profit in the future.

On September 13, 2006, AMI, Wolleben, Greenlee, and McCutcheon executed a Mutual Settlement Agreement and Release Agreement (“Settlement Agreement”), effective December 31, 2005, which, inter alia, provided for the transfer of Greenlee’s and Wolleben’s AMI stock to McCutcheon and a mutual release of claims.  It also included a number of representations by Greenlee and Wolleben regarding AMI’s assets and liabilities, as well as revenue and compensation that they received after May 2002 related to their AMI employment.  The Settlement Agreement also transferred equity interest in various contracts to the individual shareholders, and included a consulting agreement for Greenlee and Wolleben to work for AMI on future projects.  Before the transfer, Greenlee and Wolleben owned slightly more than 50% of AMI.

AMI subsequently filed suit against Torch alleging various causes of action, including trade secret misappropriation, conversion, quantum meruit, unjust enrichment, breach of fiduciary duty and usurping corporate opportunities, conspiracy, and aiding and abetting, arising from Torch’s alleged misappropriation and conversion of AMI’s proprietary information and intellectual property in concert with Greenlee, Wolleben, and Telsus.  Notably, AMI did not assert a claim of ownership with respect to the Torch Energy Contract. Torch answered with a general denial and raised affirmative defenses of settlement, estoppel, third party beneficiary, release, waiver, ratification, sanctions, ambiguity, responsible third party, and agency. 

Torch subsequently filed a traditional motion for summary judgment arguing that AMI had no claim as a matter of law because it knowingly relinquished any rights or claims that it may have had with respect to the Torch Energy Contract when it executed the Settlement Agreement.[3] 

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Advanced Micromagnetics, Inc. v. Torch Energy Advisors, Inc. Torch E&P Company Rockport Resources Capital Corp. And NM Back Nine Exploration Partners, LLC, (Tex. Ct. App. 2011).

Advanced Micromagnetics, Inc. v. Torch Energy Advisors, Inc. Torch E&P Company Rockport Resources Capital Corp. And NM Back Nine Exploration Partners, LLC (Advanced Micromagnetics, Inc. v. Torch Energy Advisors, Inc. Torch E&P Company Rockport Resources Capital Corp. And NM Back Nine Exploration Partners, LLC) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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