Golden Eagle Resources v. EQT Production

CourtSuperior Court of Pennsylvania
DecidedMarch 20, 2025
Docket261 WDA 2024
StatusUnpublished

This text of Golden Eagle Resources v. EQT Production (Golden Eagle Resources v. EQT Production) 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
Golden Eagle Resources v. EQT Production, (Pa. Ct. App. 2025).

Opinion

J-A05004 & 005-25

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

GOLDEN EAGLE RESOURCES II, LLC : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : EQT PRODUCTION COMPANY : : Appellant : No. 261 WDA 2024

Appeal from the Order Entered February 8, 2024 In the Court of Common Pleas of Greene County Civil Division at No(s): No. 134 AD 2023

SILTSTONE RESOURCES, LLC : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : EQT PRODUCTION COMPANY : : Appellant : No. 413 WDA 2024

Appeal from the Order Entered March 27, 2024 In the Court of Common Pleas of Greene County Civil Division at No(s): 578 AD 2023

BEFORE: MURRAY, J., KING, J., and FORD ELLIOTT, P.J.E. *

MEMORANDUM BY MURRAY, J.: FILED: MARCH 20, 2025

In these consolidated appeals, EQT Production Company (Appellant)

appeals from the orders dismissing its preliminary objections seeking to

dismiss the complaints filed by Golden Eagle Resources II, LLC (GER) (No. 261

____________________________________________

* Retired Senior Judge assigned to the Superior Court. J-A05004 & 05-25

WDA 2024), and Siltstone Resources, LLC (Siltstone) (No. 413 WDA 2024),

and denying its requests to compel arbitration of the parties’ disputes in

accordance with their respective lease agreements. After careful

consideration, we affirm the trial court’s orders.

GER’s Appeal (261 WDA 2024)

GER commenced its action against Appellant by a writ of summons filed

on March 16, 2023. On May 3, 2023, GER filed its civil complaint. Appellant

preliminarily objected to the complaint and, with leave of the trial court, GER

filed an amended complaint on September 8, 2023.

As alleged in GER’s amended complaint, on May 2, 2017, GER entered

into a lease agreement (GER Lease) whereby it leased its oil and gas interests

underlying two parcels of real property located in Greene County (the GCPs),

Pennsylvania, to LOLA Drilling I, LLC (LOLA). Amended Complaint, 5/2/17, ¶

3. Appellant subsequently acquired LOLA’s interests in the GER Lease. Id. ¶

4.

However, the GER Lease also specified criteria that, if met, would

maintain its effect beyond the primary term. Id. According to the amended

complaint,

[t]he 2017 [GER] Lease remains operative beyond its primary term if its “Leasing Term” Addendum is satisfied, which required (i) actual drilling operations … being conducted on the [GCPs] or lands pooled therewith, or (ii) oil or gas, or their constituents, are being produced in paying quantities from the Leased Premises or lands pooled therewith.

Id. ¶ 14. The GER Lease defined “operations” in an addendum (Addendum):

-2- J-A05004 & 05-25

Operations

“Actual drilling operations” shall be deemed to have commenced only after a derrick, a rig, or machinery capable of drilling an oil and/or gas well to its permitted depth is both “spudded-in” and rotating under power on the Leased Premises, or lands pooled therewith, at the location for a permitted well. Whenever the provisions of this Lease refer to “commence” or “commencement” of a well, it is intended to mean the commencement of the actual drilling operations for such well. For purposes hereof, a well shall be deemed to have been completed (and, therefore, actual drilling operations ceased as to that well) on the earliest of the following dates: (i) the date on which the well is plugged and abandoned as a dry hole, (ii) the date thirty (30) days after the date on which the well reached total depth (or, in the case of a Horizontal Well, the date the well has been drilled to the terminus of the lateral portion of the wellbore), the (iii) the date certified to the state oil and gas regulatory agency of jurisdiction where the Leased Premises is located, as the date a well has been completed as a producing well, or (iv) nine (9) months from such commencement date. “Actual reworking operations” shall mean reentry into a previously completed and producing well and actual work in the hole in a good and workmanlike manner and prosecuted with reasonable diligence.

Id. ¶ 15 (citation omitted). Thus, GER asserted that under the Addendum,

“actual drilling operations” are deemed completed at the earliest of four

possible dates:

a. The date on which the well is plugged and abandoned as a dry hole;

b. The date thirty days after the date on which the well reached a total depth[;]

c. The date certified to the state as the date a well has been completed as a producing well; or

d. Nine months from the commencement date.

Id. ¶ 20.

-3- J-A05004 & 05-25

GER averred that the GER Lease expired as to the following GCPs:

a. Greene County Tax Parcel 29-05-0103: 154.345 acres [(Parcel 103);]

b. Greene County Tax Parcel 23-04-152-A: 20 acres [(Parcel 152A) (collectively, the expired parcels)].

Id. ¶ 16. The expired parcels are included within the boundaries of the

following pooled units: Parcel 103 is included in Pooled Unit - Polecat NS 4;

and Parcel 152A is included in Pooled Unit – South Soles 2. Id. ¶ 20.

GER asserted that wells in both pooled units commenced on September

15, 2020. Id. at 21. Therefore, under the Addendum, the wells were

considered “completed” prior to the expiration of the primary terms, as more

than nine months had elapsed since their commencement. Id. ¶ 22. As such,

GER alleged, no actual drilling operations would satisfy the requirements

necessary to keep the GER Lease in effect as to Parcel 103. Id. ¶ 23.

With regard to wells in the South Soles 1 Unit or South Soles 2 Unit,

GER averred that the wells were commenced in late March 2021 or early April

2021. Id. ¶ 24. According to GER, wells in the South Soles 1 Unit and South

Soles 2 Unit were drilled to their total depths of their horizontal wellbores by

December 1, 2021. Id. ¶ 25. GER asserted these wells were considered

“completed” before the expiry of the lease’s primary term, because of the

passage of nine months since the wells reached their total depth. Id. ¶ 26.

GER further asserted that, at the end of the primary term of the GER

Lease, “there was no hydrocarbon production in paying quantities from either

-4- J-A05004 & 05-25

the South Soles 1 Unit or the South Soles 2 Unit” to maintain the lease as to

Parcel 152A. Id. ¶ 27. Thus, GER averred the GER Lease terminated as to

the expired parcels because of Appellant’s “operational conduct and lack of

production in paying quantities[,]” as required to extend the GER Lease

beyond its primary term. Id. ¶ 28.

GER asserted four counts in its amended complaint. In Count I, GER

alleged that Appellant breached the GER Lease. According to GER, Appellant

“produces hydrocarbons from the [GCPs] from lands unitized therewith.” Id.

¶ 33. However, GER averred that Appellant

has not paid GER its royalty due under the [GER Lease] for the [GCPs] the royalty rate stipulated in the 2017 [GER] Lease[,] nor in the manner required in the [GER Lease,] because the royalty is not paid at the 18% rate with no deductions that is set forth in the “Royalty” Addendum to the [GER Lease].

[Appellant’s] failure to pay GER its royalty for [the GCPs] under the terms of the [GER Lease] is a breach of the [GER Lease] and has damaged GER by resulting in a royalty underpayment to GER.

Id. ¶¶ 35-36 (paragraph designations omitted). GER asserted that each

failure to pay the required royalty rate constituted a separate breach of the

GER Lease, and that the unpaid amounts are in excess of the arbitration limits.

Id. ¶¶ 37-38.

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Golden Eagle Resources v. EQT Production, Counsel Stack Legal Research, https://law.counselstack.com/opinion/golden-eagle-resources-v-eqt-production-pasuperct-2025.