Francis, Algenard v. Coastal Oil & Gas Corporation

CourtCourt of Appeals of Texas
DecidedMay 29, 2003
Docket01-01-00457-CV
StatusPublished

This text of Francis, Algenard v. Coastal Oil & Gas Corporation (Francis, Algenard v. Coastal Oil & Gas Corporation) 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
Francis, Algenard v. Coastal Oil & Gas Corporation, (Tex. Ct. App. 2003).

Opinion



In The

Court of Appeals

For The

First District of Texas

____________


NO. 01-01-00457-CV


ALGENARD FRANCIS, Appellant


V.


COASTAL OIL & GAS CORPORATION, Appellee


* * *

COASTAL GAS CORPORATION, Appellant



ALGENARD FRANCIS, Appellee





On Appeal from the 215th District Court

Harris County, Texas

Trial Court Cause No. 99-20235





O P I N I O N

          Appellant, Algenard Francis, sustained serious personal injuries in an explosion that occurred while he was working as an independent subcontractor on the premises of appellee, Coastal Gas Corporation (Coastal). Having settled with another subcontractor, Acock Engineering, Francis proceeded to trial solely against Coastal. A jury awarded Francis damages, but the trial court set that verdict aside and rendered a take-nothing judgment in Coastal’s favor, in accordance with chapter 95 of the Civil Practice and Remedies Code. Francis presents seven issues. In support of his contention that the trial court erred by setting aside the jury’s verdict, Francis argues that chapter 95 does not apply because this is an ordinary negligence case in which the record establishes that Coastal was negligent, and also because the trial court’s application of chapter 95 violates the open-courts provision of the Texas Constitution. Francis further contends that the trial court erred by granting Coastal leave to file a trial amendment to plead chapter 95 and by granting partial summary judgment in Coastal’s favor under chapter 16, section 3.2 of the Administrative Code, a Railroad Commission regulation governing fire prevention and swabbing. Francis also challenges the legal sufficiency of the evidence to support the jury’s finding that Acock was negligent. Coastal brings a conditional cross-appeal to challenge the sufficiency of the evidence, the jury charge, and evidentiary rulings. We affirm.

Facts and Procedural History

          Francis was working for Reeled Tubing on a coiled-tubing washing of the M. Salinas No. 6 well on Coastal’s premises when gas that had formed over an open top collecting tank exploded suddenly. The explosion resulted when the diesel motor that had been generating the power for the coiled tubing process backfired and ignited the gas over the tank. The motor had backfired once before the explosion.

          Coastal held the mineral leases on the M. Salinas No. 6 well and operated the well. Coastal had rights, under these leases, to use the surface to access the minerals. Coastal hired others to drill and to service the wells. Coastal had a written subcontract with Acock to provide on-site consulting at the well site. Clauses four and 16 of this contract included Acock’s warranties to perform its work safely, efficiently, and economically. Paragraph eight recognized Acock’s status as an independent contractor with none of the benefits that Coastal normally extended to its employees. Clause eight recognized Coastal’s rights to oversee and inspect Acock’s services, but disclaimed association or connection with actual performance of the details of those services, and placed financial responsibility for all labor, materials, and other expenses on Acock. Acock had an extensive safety manual.

          Acock, in turn, contracted with another independent contractor, Alan Bickham. Bickham worked as a consultant whose chief responsibilities were to coordinate the activities of many independent contractors at the well site and to report to Coastal about those activities. In that capacity, he was known, in oil-field vernacular, as the “company man” for Coastal. His contract was with Acock, however, and he collected his wages from Acock. He had no contract with Coastal.

          Coastal also subcontracted with Reeled Tubing to perform coiled-tubing work at the site. Reeled Tubing’s contract with Coastal contained specific clauses, identical to those contained in the Acock subcontract, by which Reeled Tubing warranted to perform work safely, efficiently, and economically. The contract acknowledged that Reeled Tubing was an independent contractor and was not entitled to Coastal employee benefits. Reeled Tubing had its own manual of departmental operating guidelines.

          Coastal, in addition, had internal operating guidelines that applied to wells within its Corpus Christi district, in which the M. Salinas No. 6 well was located. The purpose of these guidelines was to make the field consultant aware of factors to be considered while performing different types of work. The operating guidelines that pertained to coiled-tubing operations stated that tanks “should be placed 100 feet downwind of wellhead and any source of ignition.” Those guidelines applied to Reeled Tubing’s work, but were apparently never conveyed to Bickham.

          When gas at the M. Salinas No. 6 well was not flowing as expected, Coastal formulated an 11-point outline of a “Procedure to Run Tubing” to rehabilitate the well and increase the flow of gas by installing smaller diameter tubing inside the larger, existing casing. Reeled Tubing undertook step 10 of this plan after the first nine steps were completed by others. Reeled Tubing’s work involved cleaning the well by conducting a “coiled tubing wash out.” In this process, an engine pumped debris out of the well and into a receptacle, in this case, an open top tank. The debris included gas, water, and sand.

          Pool Well Servicing (Pool) owned the open top tank Reeled Tubing was to use at the M. Salinas No. 6 well. Before Reeled Tubing was to begin its step 10 of the “Procedure to Run Tubing,” Bickham instructed Pool to move the tank from another well site, where Reeled Tubing was washing out another well, to the M. Salinas No. 6 well. Bickham proposed to meet the Pool driver at the M. Salinas No. 6 well, but was delayed at another well site. When the driver contacted Bickham by cell phone, asking where to leave the tank, Bickham gave instructions based on his recollection of where Reeled Tubing had spotted its equipment on other jobs. Bickham explained that he typically allowed the subcontractors to place their equipment safely and he sought “to fulfill the wishes of Reeled Tubing’s on-site supervisor” in the instructions he gave. Bickham indicated landmarks (a heater and two coolers), but had difficulty communicating with either the dispatcher or the driver.

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