Frye, P. v. Penn View Exploration, Inc.

CourtSuperior Court of Pennsylvania
DecidedMay 22, 2024
Docket919 WDA 2023
StatusUnpublished

This text of Frye, P. v. Penn View Exploration, Inc. (Frye, P. v. Penn View Exploration, Inc.) is published on Counsel Stack Legal Research, covering Superior Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Frye, P. v. Penn View Exploration, Inc., (Pa. Ct. App. 2024).

Opinion

J-A06029-24

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

PAUL F. FRYE AND EDWARD FRYE : IN THE SUPERIOR COURT OF : PENNSYLVANIA Appellants : : : v. : : : PENN VIEW EXPLORATION, INC., : No. 919 WDA 2023

Appeal from the Order Entered July 7, 2023 In the Court of Common Pleas of Westmoreland County Civil Division at No(s): 2105 of 2021

BEFORE: LAZARUS, P.J., PANELLA, P.J.E., and BECK, J.

MEMORANDUM BY PANELLA, P.J.E.: FILED: May 22, 2024

In this oil and gas lease dispute, Paul F. Frye and Edward Frye (“the

Fryes”) appeal from the order of July 7, 2021, which denied their motion for

summary judgment, granted the motion for summary judgment filed by Penn

View Exploration, Inc., and entered judgment in favor of Penn View on its

counterclaim. We affirm in part, reverse in part, and vacate the entry of

judgment.

The trial court summarized the procedural history of this case as follows:

On or about May 16, 2008, the Fryes entered into a lease with Atlas America, LLC regarding the oil and gas rights on their 69.4-acre parcel in Salem Township, Pennsylvania. On approximately February 17, 2011, Chevron Appalachia, LLC obtained the interests of Atlas under the lease by way of merger. In 2012, Chevron created an unconventional gas production unit on the land known as the Frye Unit, and created a drill pad site covering approximately three acres of the property. Chevron drilled three wells on this pad. J-A06029-24

Chevron began producing gas from these wells in late 2012. Production continued through July 1, 2018, when a necessary connecting Equitrans pipeline was abandoned by Equitrans. Chevron did not find an alternative pipeline, and the wells have not produced since July 1, 2018. Present Defendant, Penn View, acquire[d] the Frye Unit assets from Chevron on March 1, 2019. Since that time, Penn View has obtained rights of way from neighboring property owners and obtained a $500,00.00 loan to finance the construction of a connecting pipeline. No gas has been produced since July 1, 2018 because the well has not been connected to the new pipeline. Penn View maintains that the well is still capable of producing at paying quantities if it is connected.

By letter dated May 20, 2021, [the Fryes notified Penn View of their intent to terminate the lease. Penn View responded with] a check for back payment of shut-in rentals. The Frye’s refused to accept this payment by letter dated June 7, 2021. On June 9, 2021, the Fryes initiated this suit, seeking declaratory and injunctive relief terminating the lease. An amended complaint was filed on July 21, 2021. Penn View answered the amended complaint and set forth a counterclaim asserting that the Fryes had breached the lease by failing to provide access to the property and failed to provide Penn View notice and opportunity to cure any alleged breach. ...

Both parties have filed motions for summary judgment … . In their motion, [the Fryes] argue that no issues of material fact remain regarding the Fryes’ decision to terminate the lease, and so they are entitled to a declaratory judgment stating that the lease is terminated. [Penn View] argues that because the lease is capable of producing in paying quantities in their judgment, the lease has not terminated in the manner asserted by [the Fryes]. In its motion, [Penn View] additionally argues that [the Fryes] did not follow the contractually mandated procedure for termination of [the] lease and so they have breached the lease as [a] matter of law.

Trial Court Order, 7/7/23, at 2-3. In an order dated July 7, 2023, the trial

court denied the Fryes’ motion for summary judgment, dismissed their

complaint, and granted Penn View summary judgment on its counterclaim for

breach of contract. This timely appealed followed.

-2- J-A06029-24

The Frye’s present the following issues for our review:

1. Was the oil and gas lease in question terminated on its own terms when [Penn View] failed to timely exercise its option to extend the term of the lease in the manner required in the event of shut-in?

2. [Were the Fryes] required to give [Penn View] notice of breach and an opportunity [to cure] under the provisions of a terminated oil and gas lease; and, if so, whether [the Fryes] provided adequate notice?

3. Where the trial court failed to consider whether the supposed breach of the oil and gas lease in question had caused the non- breaching party damages foreseeable by the breaching party when the lease was made, whether the trial court erred by entering summary judgment of breach in favor of [Penn View]?

Appellants’ Brief at 4-5.

In their first issue, the Fryes argue the trial court erred in denying their

motion for summary judgment. See id. at 20-30. They contend that the Lease

terminated when Penn View failed to extend the term of the Lease during the

period of shut-in. To support their claim, the Fryes explain that since July 1,

2018, the wells have been without production and shut-in, resulting in the

Fryes not being paid any production royalties since then. See id. at 22. The

Fryes contend that Penn View had the right to extend the term of the Lease

during the shut-in period by tendering payments of the shut-in royalty. See

id. at 25. They conclude, however, that the Lease became null and void when

Penn View failed to act in accordance with the Lease. See id. at 27.

Our standard of review of an order granting or denying summary

judgment is well-settled:

-3- J-A06029-24

We view the record in the light most favorable to the nonmoving party, and all doubts as to the existence of a genuine issue of material fact must be resolved against the moving party. Only where there is no genuine issue as to any material fact and it is clear that the moving party is entitled to a judgment as a matter of law will summary judgment be entered. Our scope of review of a trial court’s order granting or denying summary judgment is plenary, and our standard of review is clear: the trial court’s order will be reversed only where it is established that the court committed an error of law or abused its discretion.

Daley v. A.W. Chesterton, Inc., 37 A.3d 1175, 1179 (Pa. 2012) (citation

omitted).

Instantly, we are called upon to review the trial court’s interpretation of

the Lease. Applicable to this lease dispute are the principles of contract and

property law.

[A]n oil and gas lease reflects a conveyance of property rights within a highly technical and well-developed industry, and thus certain aspects of property law as refined by and utilized within the industry are necessarily brought into play. The Supreme Court has aptly observed that the traditional oil and gas “lease” is far from the simplest of property concepts. In the context of oil and gas leases, the title conveyed is inchoate and initially for the purpose of exploration and development. If development during the primary term is unsuccessful, no estate vests in the lessee. If oil or gas is produced, the right to produce becomes vested and the lessee has a property right to extract the oil or gas. In such circumstances the lessee will be protected in accordance with the terms of the lease and will be required to operate the leasehold for the benefit of both parties.

McCausland v. Wagner, 78 A.3d 1093, 1100-01 (Pa. Super. 2013) (citations

omitted). “Royalty-based leases are to be construed in a manner designed to

promote the full and diligent development of the leasehold for the mutual

benefit of both parties.” Id. (citation omitted).

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Frye, P. v. Penn View Exploration, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/frye-p-v-penn-view-exploration-inc-pasuperct-2024.