Asher Land and Mineral, Ltd v. Nami Resources Company, L.L.C.

CourtKentucky Supreme Court
DecidedAugust 16, 2018
Docket2016-SC-0235
StatusUnpublished

This text of Asher Land and Mineral, Ltd v. Nami Resources Company, L.L.C. (Asher Land and Mineral, Ltd v. Nami Resources Company, L.L.C.) is published on Counsel Stack Legal Research, covering Kentucky Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Asher Land and Mineral, Ltd v. Nami Resources Company, L.L.C., (Ky. 2018).

Opinion

RENDERED; AUGUST 16, 2018 TO BE PUBLISHED

of

2015- SC-000489-DG 2016- SC-000235-DG {^telnian. 1>C

NAMI RESOURCES COMPANY, APPELLANTS/CROSS-APPELLEES L.L.C., TRUST ENERGY COMPANY, L.L.C., VINLAND ENERGY OPERATIONS, L.L.C., VINLAND ENERGY EASTERN, L.L.C., AND VINLAND ENERGY GATHERING, L.L.C., AND ASHER LAND AND MINERAL, L.T.D.

ON REVIEW FROM COURT OF APPEALS V. CASE NOS. 2012-CA-000762-MR, 2012-CA-001438-MR, AND 2012-CA-001439-MR BELL CIRCUIT COURT NO. 06-CI-00566

ASHER LAND AND MINERAL, LTD, APPELLEES/CROSS-APPELLANTS VANGUARD NATURAL RESOURCES, LLC, VANGUARD NATURAL GAS, LLC, AND NAMI RESOURCES COMPANY, LLC

OPINION OF THE COURT BY JUSTICE VENTERS

AFFIRMING IN PART, VACATING IN PART, REVERSING, AND REMANDING

Appellants, Nami Resources Company, LLC, and four associated entities^

(collectively identified as “Nami”) appeal from an opinion of the Court of

Appeals which upheld a jury verdict against Nami in the sums of

1 The five Appellants are Nami Resources Company, LLC; Trust Energy Company, LLC; Vinland Energy Eastern, LLC; Vinland Energy Operations, LLC; and Vinland Energy Gathering, LLC. $1,308,403.60 in compensatory damages and $2,686,000.00 in punitive

damages. The verdict arises from an action brought by Appellees, Asher Land

and Mineral, Ltd., and two other entities2 (collectively identified as “Asher”)

asserting that Nami had violated its contractual obligations by fraudulently

underpaying royalties owed under the leases that governed Nami’s extraction of

natural gas from Asher’s land.

Asher asserted its claim for unpaid royalties under two overlapping

theories: (1) breach of contract and (2) fraudulent misrepresentation of the

factors that determined the royalties owed to Asher, specifically the quantity of

gas extracted from Asher land, the actual costs associated with Nami’s

processing of the gas, and the market price for which the gas was ultimately

sold.

Nami argues on discretionary review that: (1) the Court of Appeals and

the trial court erred by failing to set aside the award of compensatory damages

which Nami contends was based upon flawed evidence which should have been

excluded by the trial court; and (2) the award of punitive damages was

improper because Asher’s claim is fundamentally a breach of contract action.

Nami contends that the judgment should be reversed, and Asher’s claims

dismissed. In the alternative, Nami argues that a new trial must be granted for

various trial errors that occurred.

2 The three Appellees are Asher Land and Mineral, Ltd.; Vanguard Natural Resources, LLC; and Vanguard Natural Gas, LLC. On cross-appeal, Asher asserts that: (1) Nami’s appeal should have been

dismissed by the Court of Appeals because Nami’s motions for post-judgment

relief preserving the issues were not timely presented in the trial court; and (2)

the trial court erroneously denied Asher’s motion to amend its complaint to

allege that Nami committed trespass by extracting gas from land not subject to

the gas leases.

For the reasons stated below, we conclude that the award of punitive

damages, for what is essentially a breach of contract, was improper and must

be vacated. Otherwise, we affirm the Court of Appeals’ decision upholding the

award of compensatory damages as determined by the trial court and jury. We

also affirm the Court of Appeals’ conclusion that Nami’s post-verdict motions

were made timely, that no errors committed during the trial warrant a setting

aside of the verdict and the granting of a new trial, and that the trial court

properly denied Asher’s motion to amend its complaint.

I. FACTUAL AND PROCEDURAL BACKGROUND

Asher acquired from its predecessors-in-interest the rights as lessor

under three separate gas leases, executed respectively in 1929, 1952, and

1953, covering certain natural gas reserves in Bell County, Kentucky. As

relevant to our review, all three leases contain essentially the same royalty

provisions. As the successor lessee under all three leases, Nami acquired the

right to extract Asher’s natural gas in return for the royalty payments

prescribed in the leases. As a result of this relationship, Nami’s gas wells on

Asher’s property became part of Nami’s network of small regional pipelines

3 connecting more than eight hundred gas wells to the larger natural gas

transmission systems operated by Columbia Gas and Delta Gas.

The dispute before us concerns the validity of Nami’s calculation of

royalties payable to Asher over a period of several years. Meters attached to

each wellhead measured and recorded the volume of natural gas extracted.

Each month, Nami sent Asher a royalty check with a report citing the volume

of gas extracted from each well, the price per thousand cubic foot unit (Mcf)

Nami received from the sale of the gas, and the post-production costs that

Nami deducted from the sales price in the royalty calculation.

As was customary in the era in which they were executed, royalties

payable under the Nami-Asher gas leases are based upon the market price for

gas sold at the wellhead, the “at the wellhead” price.3 Because of subsequent

technological and market changes, gas is no longer marketed at the well and

there is no market price for gas at the wellhead. Instead, gas is collected by the

lessee at the wellhead, processed to remove water and other impurities, and

transported with gas from other wells in the area through pipelines to a central

point of sale and distribution.

To accommodate that shift, the industry has adopted the customary and

proper business practice of calculating the lessor’s royalty by replicating an “at

3 The 1929 lease required Nami to pay to Asher “for gas from each well, while the same is sold off the premises, the equal of one-eighth of the market price of said gas, to be paid monthly.” Similarly, the 1952 and 1953 leases required Nami to pay “for gas from each well where the gas is found, the equal of one-eighth (1/8) of the gross proceeds, at the prevailing market rate, for edl gas sold, used or manufactured into gasoline, carbon black or other by-products, on or off premises.” the wellhead” price. This is done by deducting from the gross price what the

lessee receives for the gas, certain post-production expenses incurred by the

lessee to process the gas and to move it from the wellhead to the point of sale.

Known as “gathering costs” and “post-production costs,” these expenses are

generally understood to include the expenses incurred to remove water vapor

and other impurities such as carbon dioxide, nitrogen, and hydrogen sulfide

found in gas in its natural state. The gas is moved through the pipelines by

compressors which are fueled by consuming a small portion of the extracted

gas. That process results in “line loss,” meaning that less gas reaches the

market than was metered at the wellhead.

These types of costs are generally regarded as part of the natural and

unavoidable expenses associated with the production and marketing of natural

gas after it is extracted from the well. Our recent cases have made clear that

such costs are properly deducted by the lessee in calculating its royalty

obligation to the lessor. See Baker v. Magnum Hunter Production, Inc., 473

S.W.3d 588 (Ky. 2015); Appalachian Land Co. v. EQTProduction Co., 468

S.W.3d 841 (Ky. 2015). Nami and Asher agree with this industry-wide practice.

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