Emerald Oil & Gas, L.C., on Behalf of Its Working Interest Owner Saglio Partnership Ltd. v. Exxon Corporation and Exxon Texas, Inc., as Successor in Interest to Humble Oil & Refining Co.

CourtCourt of Appeals of Texas
DecidedJanuary 27, 2005
Docket13-99-00757-CV
StatusPublished

This text of Emerald Oil & Gas, L.C., on Behalf of Its Working Interest Owner Saglio Partnership Ltd. v. Exxon Corporation and Exxon Texas, Inc., as Successor in Interest to Humble Oil & Refining Co. (Emerald Oil & Gas, L.C., on Behalf of Its Working Interest Owner Saglio Partnership Ltd. v. Exxon Corporation and Exxon Texas, Inc., as Successor in Interest to Humble Oil & Refining Co.) 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.

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Emerald Oil & Gas, L.C., on Behalf of Its Working Interest Owner Saglio Partnership Ltd. v. Exxon Corporation and Exxon Texas, Inc., as Successor in Interest to Humble Oil & Refining Co., (Tex. Ct. App. 2005).

Opinion

NUMBER 13-99-757-CV

COURT OF APPEALS

THIRTEENTH DISTRICT OF TEXAS

CORPUS CHRISTI – EDINBURG


EMERALD OIL AND GAS, L.C. ON BEHALF

OF ITS WORKING INTEREST OWNER

SAGLIO PARTNERSHIP LTD.,                                                  Appellants,


v.


EXXON CORPORATION AND EXXON TEXAS, INC.,

AS SUCCESSOR IN INTEREST TO HUMBLE

OIL AND REFINING CO.,

Appellees.




On appeal from the 135th District Court

of Refugio County, Texas.





                                                 O P I N I O N


       Before Chief Justice Valdez and Justices Hinojosa and Castillo


                             Opinion by Chief Justice Valdez

          Emerald Oil & Gas, L.C. (“Emerald”) sued Exxon Corp. and Exxon Texas, Inc., as successor in interest to Humble Oil & Refining Co. (“Exxon”), for wrongful conduct in plugging and abandoning oil and gas wells in the Mary Ellen O’Connor Field near Refugio, Texas. Emerald, who held mineral leases on the wells following Exxon, alleged that Exxon intentionally sabotaged the wells and misrepresented the status of the wells in public filings made with the Texas Railroad Commission. Specifically, Emerald alleged that Exxon cut casing without pulling or attempting to pull it, left non-drillable material in wellbores, filed false W-3 plugging reports with the Texas Railroad Commission, pumped tank bottoms and other pollutants into producing or disposal zones, and plugged and abandoned the wellbores in such a manner as to make re-entry difficult if not impossible. The trial court granted a partial summary judgment for Exxon on Emerald’s statutory causes of action against Exxon. This judgment was severed, and Emerald appeals. We reverse and remand.

Background

           As an initial matter, we note that Exxon objected to the statement of facts found in Emerald’s brief on grounds that Emerald merely copied paragraphs of its petition into its brief. Accordingly, Exxon offered its own “brief statement of the undisputed facts.” Exxon’s objection fails to consider and apply the correct standard of review. In fact, we assume that all allegations and facts in the non-movant’s pleadings are true in determining whether a cause of action exists. Perry v. S.N., 973 S.W.2d 301, 303 (Tex. 1998). Accordingly, the following statement of facts is premised on the allegations and facts contained in Emerald’s pleadings.

          Exxon leased the mineral interests on several thousand acres, the Mary Ellen O’Connor Field, near Refugio. Exxon’s interest in the property spanned decades and was the result of several different leases. The oil production on the property dwindled, and Exxon attempted to renegotiate the fifty percent royalty it paid to the owners of the mineral interests. The fifty percent royalty was greater than what Exxon paid to neighboring landowners. Unsuccessful in its attempts to reduce the royalty, Exxon gradually plugged and abandoned the wells on the property. In so doing, Exxon engaged in a deliberate pattern of sabotaging the wells to prevent reentry. Exxon’s actions resulted in waste, pollution, economic loss, and loss of useful wells. Exxon further misrepresented the status of the wells and the procedures undertaken in Exxon’s public filings with the Texas Railroad Commission.

          After Exxon’s lease expired, Emerald Oil & Gas, acting on behalf of its working interest owner, Saglio Partnership, Ltd., obtained the lease of the mineral interests on the property. Emerald and the intervening royalty interest owners subsequently brought suit against Exxon alleging wrongful conduct in the development and abandonment of the oil and gas field. Emerald bases some of its causes of action against Exxon on the fact that, in determining whether to obtain the lease on the wells, Emerald relied on Exxon’s public filings with the Texas Railroad Commission. Several of Emerald’s causes of action were based on the Texas Natural Resources Code, specifically including, inter alia, section 89.011, governing the duty of an operator, section 85.045, prohibiting waste in the production, storage, or transportation of oil and gas, and section 85.321, providing a suit for damages. See Tex. Nat. Res. Code Ann. § 89.011 (Vernon Supp. 2004-05), § 89.011 (Vernon 2001); § 85.321 (Vernon 2001).

          Exxon filed an amended motion for partial summary judgment against Emerald and the intervenors under rule 166a(c) governing traditional summary judgments. See Tex. R. Civ. P. 166a(c). It argued that it was entitled to summary judgment “as a matter of law” because: (1) a lessee who has elected to surrender its lease has no obligation to potential future lessees or operators; (2) there is no private cause of action for breach of a regulatory law duty to plug a well in a particular fashion; (3) there is no private cause of action for breach of any regulatory law duty not to commit waste; (4) the facts alleged by Emerald and the intervenors do not give rise to a claim for tortious interference with economic opportunity; and (5), in the alternative only, if the intervenors have any claim against Exxon for failure to properly plug the wells, that cause of action sounds only in contract, not in tort.

           The trial court granted Exxon’s motion, in part, by ruling that Exxon:

owed no duties under Tex. Nat. Res. Code §§89.011, 85.045, 85.046, 85.321, and 16 Tex. Admin. Code §3.14(c)(1) (1998) (Tex. R.R. Comm’n, Plugging) or their respective prior versions, to potential future working interest owners, such as Emerald Oil & Gas L.C. acting on behalf of its working interest owner, Saglio Partnership, Ltd., that would give rise to a cause of action by Emerald Oil & Gas L.C., acting on the behalf of its working interest owner Saglio Partnership Ltd., against Defendants for negligence per se; for breach of a regulatory law duty to properly plug a well; or for breach of a regulatory law duty not to commit waste.


See Tex. Nat. Res. Code Ann. §§ 89.011 (Vernon Supp. 2004-05), 85.045 (Vernon 2001), 85.046 (Vernon 2001), 85.321 (Vernon 2001), 16

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Emerald Oil & Gas, L.C., on Behalf of Its Working Interest Owner Saglio Partnership Ltd. v. Exxon Corporation and Exxon Texas, Inc., as Successor in Interest to Humble Oil & Refining Co., Counsel Stack Legal Research, https://law.counselstack.com/opinion/emerald-oil-gas-lc-on-behalf-of-its-working-interest-owner-saglio-texapp-2005.