Heirs of Peter Hill v. James H. Welch Commissioner of Conservation of the State of Louisiana Office of Conservation

CourtLouisiana Court of Appeal
DecidedApril 16, 2021
Docket2020CA0887
StatusUnknown

This text of Heirs of Peter Hill v. James H. Welch Commissioner of Conservation of the State of Louisiana Office of Conservation (Heirs of Peter Hill v. James H. Welch Commissioner of Conservation of the State of Louisiana Office of Conservation) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Heirs of Peter Hill v. James H. Welch Commissioner of Conservation of the State of Louisiana Office of Conservation, (La. Ct. App. 2021).

Opinion

STATE OF LOUISIANA

COURT OF APPEAL

j' c ti FIRST CIRCUIT

2020 CA 0887

HEIRS OF PETER HILL

VERSUS

JAMES H. WELSH COMMISSIONER OF CONSERVATION OF THE STATE OF LOUISIANA OFFICE OF CONSERVATION

Judgment Rendered: APR 1 6 2021

On Appeal from the Nineteenth Judicial District Court In and for the Parish of East Baton Rouge State of Louisiana No. 634, 111

Honorable Trudy M. White, Judge Presiding

Brent K. Delee Counsel for Plaintiffs/ Appellees Kirby J. Guidry Heirs of Peter Hill Baton Rouge, Louisiana

F. Jonathan Rice Counsel for Defendant/ Appellant John W. Adams Richard P. Ieyoub, Commissioner of Daniel D. Henry, Jr. Conservation of the State of Louisiana Baton Rouge, Louisiana Office of Conservation

BEFORE: GUIDRY, MCCLENDON AND LANIER, JJ. McCLENDON, J.

This is an appeal from a district court's judgment that reversed an order issued

by the Commissioner of Conservation of the State of Louisiana, Office of Conservation

the Commissioner), concerning the creation of drilling and production units. For the

reasons that follow, we reverse the judgment of the district court and reinstate the

Commissioner' s decision.

FACTS AND PROCEDURAL HISTORY

In 2007, the Office of Conservation authorized drilling and oil production on

property owned by A. Wilbert's Sons, L. L. C. ( Wilbert' s Sons) in West Baton Rouge

Parish near Maringouin, which was under lease with TMR Exploration, Inc. ( TMR).

Wilbert's Sons Well 93 No. 1 was completed and began producing in 2008. In 2010,

TMR transferred its interests to Park Exploration, Inc., who sold to Vitol Resources, Inc.

Vitol) in 2012.

On March 11, 2014, Vitol filed an application with the Commissioner to create

two 320 -acre compulsory drilling and production units for the Cockfield Zone, Reservoir

A, Erwinville Field in West Baton Rouge Parish, including the property around Wilbert's

Sons Well 93 No. 1. 1 The involved landowners, Wilbert' s Sons, the Heirs of Peter Hill

the Hills) and Charles Salemi, countered with proposals of their own. Vitol and

Wilbert's Sons reached an agreement regarding the size of the units, but the Hills and

Salemi presented a proposal for a single unit of approximately 167 acres around

Wilbert's Sons Well 93 No. 1. Following a hearing on the matter, the application

presented by Vitol was adopted by the Commissioner, pursuant to Order No. 1575- A,

which confirmed CF RA SUA and CF RA SUB, the two 320 -acre units. The Hills and

Salemi then requested a rehearing with the Commissioner to consider additional

evidence, which was denied, and on October 10, 2014, the Hills timely filed an appeal

of Order No. 1575- A to the district court. The Commissioner answered the petition and

filed a certified copy of the administrative record into the district court record.

1 At the time the application was made, James H. Welsh was the Commissioner of Conservation. Richard P. Ieyoub is the current Commissioner.

AA Thereafter, on August 23, 2017, the Hills filed in the district court a rule to show

cause why a rehearing before the Commissioner should not be ordered. The Hills

argued that that the Commissioner' s denial of their request for rehearing was arbitrary

and capricious and contrary to the law and evidence, in light of " the amount of

important new evidence, unconsidered issues, and other good grounds." On November

14, 2017, the district court granted the Hills' request and ordered the Commissioner to

grant the Hills a rehearing. On December 18, 2017, the district court signed its

judgment and ordered that the matter be remanded for rehearing and limited to the

record filed by the Commissioner " in these proceedings, together with all exhibits and

material evidence filed by [ the Hills] in this proceeding." On June 26, 2018, the

Commissioner conducted the rehearing and considered the additional evidence offered

by the Hills. On July 30, 2018, the Commissioner issued Order No. 1575- A- 1, effective

on and after June 26, 2018, upholding and confirming its previous order.Z

On September 12, 2018, the Hills filed a Petition for Appellate Review of Order

No. 1575- A- 1 in the same docket number as their petition for appellate review of Order

No. 1575- A. In response, the Commissioner filed peremptory exceptions of res judicata

and no cause of action, as well as the dilatory exception of non -conformity with the

requirements of LSA- C. C. P. arts. 891 and 893. The district court denied the exceptions

on July 30, 2019.

Subsequently, on June 25, 2019, the Hills filed a rule to show cause why Order

No. 1575- A- 1 should not be modified. On August 26, 2019, the district court heard the

Hills' rule to show cause and took the matter under advisement. On May 27, 2020, the

district court issued written reasons, finding that the substantial rights of the Hills had

been prejudiced, as the Commissioner' s decision was arbitrary and capricious and an

abuse of discretion, and ordered the Commissioner to adopt the 167 -acre unit as

proposed by the Hills. The district court signed a judgment on July 3, 2020, in

conformity with its ruling.

2 When Order No. 1575- A- 1 became effective, Urban Oil and Gas Group, LLC had been confirmed as the operator of the two units, replacing Vitol.

9 The Commissioner appealed and assigned the following as error:

1. The district court erred in denying the peremptory exceptions raising the

objections of res judicata and no cause of action when the Hills untimely filed

their petition for appellate review of Order No. 1575- A- 1, by failing to follow

the procedures set forth in LSA- R. S. 30: 12 in perfecting their appeal.

2. The district court erred in substituting its judgment for that of the expertise

of the Commissioner in overturning Order No. 1575- A- 1 in finding that the

record did not support two 320 -acre drilling and production units and

substituting the Hills' proposed 167 -acre unit that is unsupported by the

evidence.

3. The district court erred in holding the Commissioner' s exclusion of evidence

was arbitrary and contrary to law by imposing Code of Civil Procedure and

Louisiana Code of Evidence rules on an administrative hearing when the

Commissioner has its own procedural rules for conducting hearings.

DISCUSSION

The Office of Conservation, within the Department of Natural Resources,

exercises the functions of the state with respect to the regulation, conservation, and

use of the natural resources of the state, which are not specifically within the

jurisdiction of other state departments or agencies. LSA- R. S. 36: 358A and 36: 358C. 3

The Commissioner of Conservation has jurisdiction and authority over all persons and

property necessary to enforce effectively all laws relating to the conservation of oil or

gas, and has authority to make, after notice and hearings as provided by law, any

reasonable rules, regulations, and orders that are necessary from time to time in the

proper administration and enforcement of the conservation laws. LSA- R. S. 30: 1; LSA-

R. S. 30: 4; Davidson v. Welsh, 10- 2213 ( La. App. 1 Cir. 6/ 17/ 11), 2011 WL 24482261

at * 3 ( unpublished), writ denied, 11- 1590 ( La. 10/ 7/ 11), 71 So. 3d 318.

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Related

Summers v. Sutton
428 So. 2d 1121 (Louisiana Court of Appeal, 1983)
Louisiana Environmental Action Network v. Welsh
224 So. 3d 383 (Louisiana Court of Appeal, 2017)
Simmons v. Christus Schumpert Medical Center, 2011-1591 (La. 10/7/11)
71 So. 3d 318 (Supreme Court of Louisiana, 2011)

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Heirs of Peter Hill v. James H. Welch Commissioner of Conservation of the State of Louisiana Office of Conservation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/heirs-of-peter-hill-v-james-h-welch-commissioner-of-conservation-of-the-lactapp-2021.