Eland Energy, Inc. v. Seagull Energy E&P, Inc.

CourtCourt of Appeals of Texas
DecidedFebruary 19, 2004
Docket14-02-00709-CV
StatusPublished

This text of Eland Energy, Inc. v. Seagull Energy E&P, Inc. (Eland Energy, Inc. v. Seagull Energy E&P, 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
Eland Energy, Inc. v. Seagull Energy E&P, Inc., (Tex. Ct. App. 2004).

Opinion

Reversed and Rendered in Part and Opinion filed February 19, 2004

Reversed and Rendered in Part and Opinion filed February 19, 2004.

In The

Fourteenth Court of Appeals

____________

NO. 14-02-00709-CV

ELAND ENERGY, INC., Appellant

V.

SEAGULL ENERGY E&P, INC., Appellee

On Appeal from the 127th District Court

Harris County, Texas

Trial Court Cause No. 99-03508

O P I N I O N

In this breach-of-contract case, we decide whether certain oil and gas operating agreements impose liability on former working-interest owners to reimburse the operator for costs paid by the operator after the former working-interest owner assigned its entire interest to a third party.  Under the unambiguous language of the agreements in question, we find no such liability.  Therefore, we reverse the trial court=s judgment to the extent it awards damages against appellant/defendant Eland Energy, Inc., and we render judgment that appellee/plaintiff Seagull Energy E&P, Inc. take nothing.


                         I. Factual and Procedural Background

Seagull Energy E&P, Inc. (hereafter, the AOperator@) is the designated operator in operating agreements relating to two oil and gas leases of submerged lands on the Outer Continental Shelf off the coast of Texas.  After the working-interest owners in these two leases entered into operating agreements regarding operations on each respective lease,  Eland Energy, Inc. acquired a working interest in both leases (collectively referred to herein as AWorking Interests@).  As part of the assignment of the Working Interests to Eland, Eland agreed to assume and be liable for a proportionate part of the obligations created by the existing offshore operating agreements pertaining to each interest. 

Less than two years after obtaining title to the Working Interests, Eland decided to have these interests sold at an auction that required no minimum bid.  In this auction, Nor-Tex Gas Corporation was the successful bidder, and under the terms of the auction, Eland (hereafter, the AAssignor@) assigned the Working Interests to Nor-Tex (hereafter, the AAssignee@), which paid $500 for each as consideration for the assignments.  As part of these assignments, the Assignee agreed to assume and be liable for a proportionate part of the obligations created by the existing offshore operating agreements pertaining to each of the Working Interests.  The trial court determined that the Assignor validly assigned the Working Interests to the Assignee, and the Operator does not contend otherwise on appeal.

The Assignee defaulted in its obligations under the operating agreements by failing to reimburse the Operator for its share of the costs relating to the Working Interests.  The Assignee eventually filed for bankruptcy under Chapter 7 of the United States Bankruptcy Code.  After the Assignee=s default, the Operator demanded reimbursement from the Assignor.  While the Assignor owned the Working Interests, it reimbursed the Operator for its share of the operator-incurred costs; however, the Assignor refused to reimburse the Operator for costs incurred after it assigned the Working Interests to the Assignee. 


The Operator asserted breach-of-contract claims against the Assignor and the Assignee and sought reimbursement as to costs incurred after the Assignor assigned the Working Interests to the Assignee.  The Operator filed a motion for summary judgment, arguing that the Assignor and the Assignee were jointly and severally liable as a matter of law for breach of the offshore operating agreements relating to the Working Interests.  As to the Assignor, the Operator asserted (1) the Assignor was a party to these operating agreements; (2) the Assignor therefore was required to reimburse the Operator even after it assigned the Working Interests; and (3) the Assignor=s assignment of the Working Interests did not affect the Assignor=s liability under the operating agreements. 

The Assignor opposed the Operator=s summary-judgment motion and filed its own motion for partial summary judgment, asserting that, under the unambiguous language of the operating agreements, the Assignor did not have any contractual obligation to reimburse the Operator for costs incurred after the Assignor assigned the Working Interests. 

The trial court granted the Operator=s motion and denied the Assignor=s motion.  In its interlocutory summary-judgment order, the trial court ruled: (1) the Assignee is liable to the Operator for breach of the operating agreements; (2) although the Assignor assigned the Working Interests to the Assignee, as a matter of law, the Assignor remains liable for performance of its obligations under the operating agreements; and (3) the Assignor breached the  operating agreements by failing to reimburse the Operator for the proportionate share of costs relating to the Working Interests after the Assignor assigned these interests to the Assignee.


After a bench trial on the remaining issues, the trial court signed a final judgment that incorporated the court=s prior summary-judgment rulings and that made the following additional rulings:  (1) the Assignor 

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Eland Energy, Inc. v. Seagull Energy E&P, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/eland-energy-inc-v-seagull-energy-ep-inc-texapp-2004.