Cressman Tubular Products Corporation v. Kurt Wiseman Oil & Gas Ltd., and Escondido Petroleum, Inc.

CourtCourt of Appeals of Texas
DecidedSeptember 23, 2010
Docket14-08-01039-CV
StatusPublished

This text of Cressman Tubular Products Corporation v. Kurt Wiseman Oil & Gas Ltd., and Escondido Petroleum, Inc. (Cressman Tubular Products Corporation v. Kurt Wiseman Oil & Gas Ltd., and Escondido Petroleum, Inc.) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cressman Tubular Products Corporation v. Kurt Wiseman Oil & Gas Ltd., and Escondido Petroleum, Inc., (Tex. Ct. App. 2010).

Opinion

Affirmed and Opinion filed September 23, 2010.

In The

Fourteenth Court of Appeals

___________________

NO. 14-08-01039-CV

Cressman Tubular Products Corporation, Appellant/Cross-Appellee

V.

Kurt Wiseman Oil & Gas, Ltd. and Escondido Petroleum, Appellees/Cross-Appellants

SEPCO TUBULAR, INC. AND UNITED CASING, INC., Cross-Appellees

On Appeal from the 129th District Court

Harris County, Texas

Trial Court Cause No. 2005-61801

OPINION

       This is a double appeal of a case in which multiple theories of liability were asserted against four defendants for damages caused by the sale of goods for use in an oil well.  After the defendant found liable for 99% of the plaintiffs’ damages filed for bankruptcy protection, the trial court severed those claims from this case and entered judgment requiring all of the plaintiffs’ damages and attorney’s fees to be paid by the defendant that the jury found to be 1% responsible.  On appeal, that defendant contends that all of the plaintiffs’ damages sound in tort, and thus, the trial court erred in disregarding a jury finding allocating responsibility for breach of an express warranty and in awarding attorney’s fees to the plaintiffs.  The plaintiffs argue that all of their damages sound in contract, and they contend that the trial court erred in failing to disregard the jury’s finding allocating responsibility for breach of implied warranties, failing to hold the defendants jointly and severally liable, and failing to include the jury’s breach-of-contract finding as an alternative basis for the judgment against one of the defendants.  We conclude that the plaintiffs’ express-warranty claim against appellant sounds in contract, but their implied-warranty claims against the cross-appellees sound in tort; thus, the trial court did not err in disregarding the proportionate-responsibility finding as to the express warranty claim against one defendant and in refusing to disregard a similar finding as to the implied warranty claims against two other defendants.  Finally, we further conclude that the trial court did not err in refusing to include alternative bases for its judgment, and we affirm the trial court’s judgment.   

I.  Factual and Procedural Background

            Kurt Wiseman is the owner of Kurt Wiseman Oil & Gas, Ltd., which owns a working interest in the Gerdes No. 1 well in Lavaca County, Texas.  He also is the president of Escondido Petroleum, which is the well operator.  We refer to all three collectively as “Wiseman.” 

            The Gerdes No. 1 well had been shut in for some time and the existing casing was damaged, but Wiseman planned to perform a fracture stimulation to return the well to production.  In this procedure, the rock surrounding the oil reservoir is fractured by fluid mixed with increasing concentrations of proppant pumped at high pressure into the well down a tubing string, which consists of joints of pipe connected to one another by couplings.  The proppant holds the fracture open to allow oil and gas to drain into the well bore.  The proppant and fluids are then removed and oil can be produced through the same tubing string. 

            Wiseman ordered the tubing string from Cressman Tubular Products Corporation and specified that the components were to be API P110, which means that they were to meet a particular toughness standard set by the American Petroleum Institute.  Cressman ordered the tubing string from Sepco Tublar, Inc.; Sepco ordered the couplings from United Casing, Inc.; and United Casing bought the couplings from the manufacturer, Colaco Tubular Services, Inc.  When delivered by Colaco, the couplings had been painted white, which in industry custom signified that they met the API P110 standard.  United Casing sent the couplings to Sepco, and Sepco attached the couplings to the joints of pipe before shipping them to Cressman, who then shipped them Wiseman. 

A.        The Tubing String Failures

            The joints of pipe were assembled into a tubing string and used in the planned fracture stimulation in January 2004.  Because the casing in the well narrowed from 7 5/8 inches to 5 inches in diameter, wider pipe joints were used in the upper part of the tubing string and narrower pipe was used in the lower part. 

            After about sixty percent of the fluid and twenty percent of the proppant had been pumped down the well, the tubing string failed and there was a sudden dramatic loss of pressure.  The fracture stimulation could not be completed, and mud entered the formation so that a mixture of fracture fluid, proppant, and mud were mixed with the condensate that flowed from the well.  As Kurt Wiseman later testified, “The mud went into the fracture, made it to the point where the well was actually showing skin damage, which is damage near the well bore, not allowing it to flow.  So, yes, the mud was obviously damaging [the formation].”  Wiseman’s expert Richard Klem explained at trial that the “skin damage” from the mud or “positive skin” meant that the perforations in the well casing were blocked. 

            Wiseman hired consultants who were unable to find a physical obstruction to the tubing string, and eventually, a well service company was able to circulate the mud in the well[1] and remove part of the string, which was found to have lost a coupling from its upper, wider part.  The coupling could not be found, and as Kurt Wiseman later testified, he was concerned that it might have fallen to the area where the casing and tubing string narrowed such that removing the entire tubing string could allow the coupling to fall deeper into the well bore and “junk” the well,[2] potentially rendering it unusable.  Wiseman decided to leave the narrower part of the tubing string in place, and reattached the wider portion of the string to it using an “overshot packoff.”[3]  Fluids and mud were washed out from the well in sufficient quantities for the well to begin producing oil. 

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Cressman Tubular Products Corporation v. Kurt Wiseman Oil & Gas Ltd., and Escondido Petroleum, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/cressman-tubular-products-corporation-v-kurt-wisem-texapp-2010.