Helmerich & Payne International Drilling Co. v. Bopco, L.P.

CourtCourt of Appeals of Texas
DecidedDecember 1, 2011
Docket11-10-00232-CV
StatusPublished

This text of Helmerich & Payne International Drilling Co. v. Bopco, L.P. (Helmerich & Payne International Drilling Co. v. Bopco, L.P.) 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
Helmerich & Payne International Drilling Co. v. Bopco, L.P., (Tex. Ct. App. 2011).

Opinion

Opinion filed December 1, 2011

                                                                       In The

  Eleventh Court of Appeals

                                                                   __________

                                                         No. 11-10-00232-CV

HELMERICH & PAYNE INTERNATIONAL DRILLING CO., Appellant

                                                             V.

                                           BOPCO, L.P., Appellee

                                   On Appeal from the 385th District Court

                                                          Midland County, Texas

                                                  Trial Court Cause No. CV-46938

                                                                  O P I N I O N

            This case involves the interpretation of a daywork drilling contract.  The parties disagree as to the date that the 1,095-day term of the contract commenced.  Upon construing the contract, the trial court rendered summary judgment granting declaratory relief to appellee, BOPCO, L.P.[1]  The trial court declared, among other things, that the 1,095-day contract term commenced on March 20, 2007.  Appellant, Helmerich & Payne International Drilling Co. (H&P), appeals from the trial court’s summary judgment.  We affirm.

Background Facts

            In late 2005, BOPCO needed a drilling rig for the purpose of drilling wells in Colorado. H&P agreed that it would manufacture a drilling rig and then use that rig to drill wells for BOPCO.  In January 2006, representatives from BOPCO and H&P executed a daywork drilling contract.  The parties used a standard fill-in-the-blank form contract prepared by the International Association of Drilling Contractors.  The parties deleted parts of the form contract, and they made some additions to the contract. 

            Under the contract, BOPCO was the “Operator,” and H&P was the “Contractor.”  The contract provided that BOPCO had engaged H&P as an independent contractor to drill various wells on a daywork basis.  Paragraph 2 of the contract provided as follows:

2. COMMENCEMENT DATE:

     Contractor agrees to use reasonable efforts to commence operations for the drilling of the well by on or about the 20th day of March, 2007.

As shown above, the parties struck the word “by” from Paragraph 2 of the form contract.  The parties added the “on or about” language and inserted the March 20, 2007 date in Paragraph 2. Paragraph 6 of the contract provided as follows:

6. TERM:

     6.1 Duration of Contract: This Contract shall remain in full force and effect until drilling operations are completed on the well or wells specified in Paragraph 1 above, or for a term of 1095-days, or at rig release of any well being drilled by operator on the 1095th day, whichever is later, commencing on the date specified in Paragraph 2 above (subject to 27.7 Early Termination).

As shown above, the parties struck the language in the contract beginning with the word “until” and ending with the word “or.”  The parties added the term “1095-days” in the blank.  They also added, in handwriting, the words that are italicized above.

            In Paragraph 4 of the contract, BOPCO agreed to pay H&P a day rate of $23,300 per day for work performed by H&P under the contract.  By later agreement, the day rate was changed to $23,800 per day.  The contract contained an early termination provision.  Paragraph 27.7 of the contract provided, in relevant part, as follows:

27.7 Early Termination Provision:

            Operator shall have the right to terminate the Contract at any time after the date of execution of the Contract by both parties and prior to the expiration of the first 1,095 calendar days thereafter (the “Early Termination”) by giving thirty (30) days’ prior written notice to the Contractor, conditional upon Operator paying Contractor the Early Termination amount and other amounts specified below.

            In the event of Early Termination, Operator shall pay to the Contractor an Early Termination Amount equal to the number of days remaining in the 1,095 calendar day term multiplied by $14,000.  Operator shall pay in one payment (within thirty (30) calendar days of the date of Contractor’s invoice) such Early Termination amount.  The Early Termination amount is in addition to all other amounts due and owing under the Contract prior to the date of such Early Termination, including without limitation the mobilization and demobilization payments.

By later agreement, the parties increased the early termination rate to $14,500 per day.

            The parties added a typewritten liquidated damages provision to the contract.  Paragraph 27.15 of the contract provided as follows:

27.15  Notwithstanding the foregoing, in the event Commencement of Operations has not occurred by March 20, 2007 for reasons wholly within Contractor’s reasonable control, Contractor will pay Operator, as liquidated damages for such delay and not as a penalty, a sum equal to $2,500 per day (the “Delay Payment”) for each day after April 20, 2007 that Commencement of Operations has not occurred, up to a maximum of $225,000.  Such payment will be Operator’s sole remedy and Contractor will have no other liability for any delay in the Commencement of Operations.

            H&P experienced delays in manufacturing the rig and, therefore, did not commence drilling operations under the contract until June 4, 2007.  As required by Paragraph 27.15 of the contract, H&P paid liquidated damages to BOPCO in the amount of $2,500 per day covering the forty-five day period from April 20, 2007 until June 4, 2007.  The liquidated damages totaled $112,500.  When H&P commenced operations under the contract, BOPCO began paying H&P the day rate of $23,300 per day for use of the rig.

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