EOG Resources, Inc. v. Jay Petroleum, L. L. C.

CourtCourt of Appeals of Texas
DecidedJanuary 20, 2005
Docket01-03-00514-CV
StatusPublished

This text of EOG Resources, Inc. v. Jay Petroleum, L. L. C. (EOG Resources, Inc. v. Jay Petroleum, L. L. C.) 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
EOG Resources, Inc. v. Jay Petroleum, L. L. C., (Tex. Ct. App. 2005).

Opinion

Opinion issued January 20, 2005




In The

Court of Appeals

For The

First District of Texas





NO. 01-03-00514-CV





EOG RESOURCES, INC., Appellant


V.


JAY PETROLEUM, L.L.C., Appellee





On Appeal from the 189th District Court

Harris County, Texas

Trial Court Cause No. 2001-63382





MEMORANDUM OPINIONAppellant, EOG Resources, Inc. (“EOG”), formerly known as Enron Oil and Gas Co., appeals from a final summary judgment rendered in favor of appellee, Jay Petroleum, L.L.C. (Jay), on Jay’s claims arising from a purchase and sale agreement of an interest in oil and gas leases. EOG presents two issues. In its first issue, EOG contends that rendering final summary judgment in favor of Jay was reversible error because the trial court incorrectly interpreted the agreement, and because fact issues remain on all of Jay’s causes of action. In its second issue, EOG contends that Jay failed to prove that it was entitled to final summary judgment because fact issues remain on EOG’s counterclaims against Jay for fraud, negligent misrepresentation, breach of contract, unjust enrichment, and declaratory relief. We reverse and render judgment in favor of EOG.Background

          Jay, a producer of oil and gas, owned the majority of the working interest and a royalty interest in certain oil and gas leases and wells located in Jefferson County, Texas. On October 27, 1998, Jay sold all of its working interest in the leases, and the personal property on the leases, to EOG through a purchase and sale agreement. The agreement provided that, in exchange for EOG’s payment to Jay of $1 million, EOG would receive all of Jay’s interest in certain oil and gas leases, except that Jay reserved from the transfer to EOG and retained for itself an overriding royalty interest (“reserved interest”) of 2.0425% of 8/8ths net revenue interest in all oil and gas production from the leases, reduced in proportion to the difference, if any, between Jay’s actual interest in the leases and the interests Jay purported to own. Jay resigned as operator and transferred the right to receive and disburse all proceeds of production to EOG.

          Early in 2001, EOG reduced the payments to Jay after discovering that a Maxine Feinberg owned a royalty and overriding royalty interest in the lease properties. EOG claimed that, because Feinberg claimed a 0.19247% interest in the leases, to compensate Feinberg, it was necessary to reduce Jay’s overriding royalty interest. EOG further contended that the discovery of Feinberg’s interest in the leases increased the actual total lease burdens to 21.10025%, rather than 20.2205%, as represented in the agreement.

          From November 1998 to April 2001, EOG distributed a reserved interest of 2.0425% of 8/8ths net revenue interest to Jay, but EOG did not make any disbursements of money from April 2001 to October 2001. In October 2001, EOG resumed payments to Jay, but reduced the amount to compensate for the increased actual lease burdens that resulted from the discovery of Feinberg’s interest in the leases, to a rate based on a 1.254218% overriding royalty interest in the oil and gas leases and not based on the original 2.0425%.

          In December, 2001, Jay sued EOG for breach of contract, conversion, unjust enrichment, exemplary damages and attorney’s fees. EOG answered and filed counterclaims alleging fraud, breach of contract, negligent misrepresentation, unjust enrichment, exemplary damages, attorney’s fees, and cloud on the title, and also requested a declaratory judgment. In its counterclaims, EOG contended that the agreement provided (1) that Jay must deliver to EOG a 77.5% net revenue interest in the leases and properties, and (2) that Jay retained an overriding royalty interest equivalent to 22.5% of production, less the total lease burdens and reduced in proportion to the difference, if any, between Jay’s actual interest in the leases and the interests described in Exhibit “A” of the agreement. EOG contends that Jay breached the agreement by failing to deliver the net revenue interest of 77.5% promised in the agreement after the lease burdens increased due to the discovery of Feinberg’s interest in the leases.

          Jay filed a motion for summary judgment contending that its case was “entirely based upon two very clear, unambiguous documents–a ‘purchase and sale agreement’ and an assignment of oil, gas, and mineral leases and bill of sale. . . .” The relevant portions of these documents are as follows:

ARTICLE I

PURCHASE AND SALE

1.01 Purchase and Sale. Sellers agree to sell and convey and Buyer agrees to purchase and pay for the Properties (as defined in Section 1.02 below), subject to the terms and conditions of this Agreement.

1.02 Properties. All of Sellers’ right, title and interest in and to the following (collectively, the “Properties”):

(a) All of the oil, gas and other mineral leases (“Leases”), rights, privileges, obligations, and properties, including Bank One’s net profits interest, which are described or referred to in Exhibit “A” attached hereto. It is understood and agreed that Jay purports to own a 98.22% working interest in and to the Leases which is subject to a 16.92% net profits interest owned by Bank One. Sellers shall deliver a 77.5% of 8/8ths net revenue interest in the Leases. Bank One and Jay shall reserve an overriding royalty interest in the Leases equal to the difference between 22.5% of 8/8th and the total lease burdens existing as of the Effective Time hereof (the “Reserved Interest”). The Reserved Interest of Jay shall equal 2.0425% of 8/8ths net revenue interest, reduced in proportion to the difference, if any, between Sellers’ actual interest in the Leases and the interests described on Exhibit “A”.

          . . .

10.10 Conflicts. In the event that any of the terms of this Agreement conflict or are deemed to conflict with the terms of the assignments executed pursuant to Section 7.03(a) hereof, the terms of this Agreement shall prevail at the point of conflict.


(emphasis added).


          The Assignment (from Jay to EOG) reads as follows:

a. Those certain Oil, Gas and Mineral Leases which are further described on Exhibit “A”

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EOG Resources, Inc. v. Jay Petroleum, L. L. C., Counsel Stack Legal Research, https://law.counselstack.com/opinion/eog-resources-inc-v-jay-petroleum-l-l-c-texapp-2005.