Ford v. ConocoPhillips

CourtCourt of Appeals for the Fifth Circuit
DecidedSeptember 9, 2025
Docket22-20334
StatusUnpublished

This text of Ford v. ConocoPhillips (Ford v. ConocoPhillips) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ford v. ConocoPhillips, (5th Cir. 2025).

Opinion

Case: 22-20334 Document: 70-1 Page: 1 Date Filed: 09/09/2025

United States Court of Appeals for the Fifth Circuit ____________ United States Court of Appeals Fifth Circuit

FILED No. 22-20334 September 9, 2025 ____________ Lyle W. Cayce Shawn Michael Ford, Clerk

Plaintiff—Appellee,

versus

ConocoPhillips,

Defendant—Appellant,

Bedrock Petroleum Consultants, L.L.C.; Bedrock PC 1099, L.L.C.,

Intervenor Defendants—Appellants. ______________________________

Appeal from the United States District Court for the Southern District of Texas USDC No. 4:21-CV-3099 ______________________________

Before Richman, Haynes, and Graves, Circuit Judges. Priscilla Richman, Circuit Judge: *1

_____________________ * This opinion is not designated for publication. See 5th Cir. R. 47.5. 1 Catharina Haynes, Circuit Judge, concurring in the judgment only. Case: 22-20334 Document: 70-1 Page: 2 Date Filed: 09/09/2025

No. 22-20334

A consulting firm contracted to provide personnel to ConocoPhillips. The consulting firm hired Shawn Michael Ford and contracted him out to ConocoPhillips. Ford sued ConocoPhillips for alleged Fair Labor Standards Act 2 violations. Ford did not sue the consulting firm. ConocoPhillips and the consulting firm moved to compel arbitration. The district court denied the motions. Because Ford’s agreement with the consulting firm incorporated by reference an agreement with ConocoPhillips that mandated arbitration, Ford could be compelled to arbitrate his claims against ConocoPhillips. We vacate the district court’s order denying arbitration and remand for proceedings consistent with this opinion. I ConocoPhillips is an oil and natural gas exploration and production company operating throughout the United States and worldwide. ConocoPhillips contracts with staffing companies to provide it with personnel to perform necessary work, including safety consultants and environment, health, and safety workers in several states. Ford is a safety consultant in the oil and gas industry. Intervenor-Appellants Bedrock PC 1099, LLC (Bedrock PC) and Bedrock Petroleum Consultants LLC (Bedrock Petroleum) (collectively, Bedrock) specialize in providing contract staff support to oil and gas industry customers, including ConocoPhillips. Bedrock Petroleum wholly owns 100% of the membership interest of Bedrock PC, the entity that regularly entered into agreements with independent contractors for assignments to Bedrock Petroleum’s customers. Bedrock PC and Bedrock Petroleum are separate entities. In 2018, Ford (as “Consultant”) and Bedrock PC entered into a Master Consulting Agreement (MCA). The MCA stated that “Bedrock” _____________________ 2 29 U.S.C. § 203.

2 Case: 22-20334 Document: 70-1 Page: 3 Date Filed: 09/09/2025

refers to Bedrock PC. The MCA defined “Bedrock Group” as including, among other individuals and entities, “Bedrock, its parent, subsidiaries, partners, [and] affiliates.” Article 2 of the MCA says: 2. Scope of Agreement. Consultant [Ford] is made aware that Bedrock has entered into a master services agreement, company agreement or work order (collectively “MSA”) with Bedrock’s customer (“Company”). If Consultant [Ford] is hired by Company, Consultant [Ford] agrees to the provisions of the MSA as Bedrock’s contractor. A copy of the relevant MSA shall be provided to Consultant [Ford] in the offices of Bedrock upon a reasonable request. The Consultant [Ford] assumes toward Bedrock all the obligations and responsibilities that Bedrock assumes toward the Company, as set forth in the relevant MSA, insofar as applicable, generally or specifically, to Consultant’s [Ford’s] work. Article 13 of the MCA also referenced “the relevant MSA” as being incorporated by reference: 13. Entirety. This Agreement, together with any other documents incorporated by reference herein (explicitly including the relevant MSA) and/or executed therewith, is the sole and entire Agreement of the Parties with respect to the subject matter of this Agreement . . . . In 2016, two years before Ford and Bedrock PC executed the MCA, ConocoPhillips and Bedrock Petroleum executed a Master Agreement for Support Services (MSA), wherein Bedrock Petroleum agreed to provide staffing services to ConocoPhillips through independent contractors. The MSA defines “Contractor Group” to include affiliates of Bedrock

3 Case: 22-20334 Document: 70-1 Page: 4 Date Filed: 09/09/2025

Petroleum. 3 Bedrock PC is therefore part of the “Contractor Group” under the MSA. The MSA denominates individuals like Ford as “Contractor Group Personnel.” 4 The MSA provides that Bedrock Petroleum is responsible for paying Contractor Group Personnel, which includes Ford, and for determining their exempt or non-exempt status and proper payment of overtime wages. 5 ConocoPhillips therefore does not pay Ford. Ford submitted invoices to Bedrock, and Bedrock paid him by direct deposits. Bedrock Petroleum agreed to indemnify ConocoPhillips against any actual or alleged

_____________________ 3 The MSA provides: “Contractor Group” shall mean any or all of: (i) Contractor; (ii) its Affiliates; (iii) its subcontractors; and (iv) the respective agents of any of the entitles addressed in (i), (ii), and (iii) above; all the foregoing being “members of Contractor Group”. 4 The MSA provides: “Contractor Group Personnel” shall mean any or all of (i) officers and directors of, and permanent, temporary, part-time, and intermittent staff on the payrolls of, any of the members of Contractor Group; and (ii) any other individuals utilized by any member of Contractor Group to perform, oversee, direct, or accomplish its duties and obligations pursuant to this Agreement or Call-Off Orders, howsoever such individuals may be employed, contracted, or otherwise engaged. 5 The MSA provides: 6.4. Contractor shall be fully responsible for the following in respect of Contractor Group Personnel assigned to perform Work: a. ensuring the proper and timely payment of wages, overtime wages, salaries, and all other remuneration . . .; b. determination and classification of exempt or non-exempt status and proper payment of overtime wages. . . .

4 Case: 22-20334 Document: 70-1 Page: 5 Date Filed: 09/09/2025

misclassification of Contractor Personnel under the Fair Labor Standards Act (FLSA). 6 Bedrock Petroleum also agreed in the MSA that all members of the Contractor Group (which included Bedrock PC as an affiliate) would comply with all applicable laws, and Bedrock Petroleum agreed to indemnify ConocoPhillips for the failure of any member of the Contractor Group to comply with any applicable law. 7

_____________________ 6 The MSA provides: 6.8. CONTRACTOR SHALL INDEMNIFY EACH OF THE MEMBERS OF COMPANY GROUP AND THEIR RESPECTIVE BENEFIT PLANS AND FIDUCIARIES FROM AND AGAINST ANY AND ALL CLAIMS, FINES, TAXES, AND OTHER LIABILITY (INCLUDING INTEREST AND PENALTIES) ARISING OUT OF OR RESULTING FROM: ... c. ANY ALLEGED OR ACTUAL MISCLASSIFICATION OR MIS-DESIGNATION OF CONTRACTOR PERSONNEL AS (i) EXEMPT OR NON-EXEMPT UNDER THE FAIR LABOR STANDARDS ACT OF 1938; OR (ii) EMPLOYEES OF COMPANY. . . . 7 The MSA provides: 23.1. Contractor shall comply fully, and shall ensure that the other members of Contractor Group and Contractor Group Personnel shall comply fully, with all Applicable Laws . . . . SUBJECT TO ARTICLE 18, CONTRACTOR SHALL INDEMNIFY EACH OF THE MEMBERS OF COMPANY GROUP FROM AND AGAINST ANY AND ALL CLAIMS ARISING OUT OF OR RESULTING FROM ANY ACTUAL OR ALLEGED FAILURE BY ANY OF THE MEMBERS OF CONTRACTOR GROUP OR BY ANY CONTRACTOR GROUP PERSONNEL TO COMPLY WITH ANY APPLICABLE LAWS.

5 Case: 22-20334 Document: 70-1 Page: 6 Date Filed: 09/09/2025

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Ford v. ConocoPhillips, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ford-v-conocophillips-ca5-2025.