in Re: BP America Production F/K/A Amoco Production Company and Toc-Rocky Mountains, Inc

CourtCourt of Appeals of Texas
DecidedJanuary 31, 2003
Docket14-02-00871-CV
StatusPublished

This text of in Re: BP America Production F/K/A Amoco Production Company and Toc-Rocky Mountains, Inc (in Re: BP America Production F/K/A Amoco Production Company and Toc-Rocky Mountains, Inc) 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
in Re: BP America Production F/K/A Amoco Production Company and Toc-Rocky Mountains, Inc, (Tex. Ct. App. 2003).

Opinion

Petition for Mandamus Conditionally Granted and Opinion filed January 31, 2003

Petition for Mandamus Conditionally Granted and Opinion filed January 31, 2003.

In The

Fourteenth Court of Appeals

_______________

NO. 14-02-00871-CV

In re BP AMERICA PRODUCTION COMPANY,

f/k/a AMOCO PRODUCTION COMPANY and

TOC-ROCKY MOUNTAINS, INC., Relators

___________________________________________________________

ORIGINAL PROCEEDING

WRIT OF MANDAMUS

O P I N I O N

            BP America Production Company, f/k/a Amoco Production Company, and TOC-Rocky Mountains, Inc. (collectively, “BP”)[1] seek a mandamus directing the trial court to vacate its order denying BP’s motion to compel arbitration and to enter an order compelling arbitration of all issues in the underlying lawsuit (the “lawsuit”).  We conditionally grant the petition for mandamus.


Background

            The lawsuit was filed against BP by real-parties-in-interest Occidental Permian Ltd. (“LP”), a limited partnership, and Occidental Permian Manager, L.L.C. (“LLC”), its general partner.  LLC and LP seek a declaration that they own and are entitled to exercise certain contractual “call” rights (the “calls”), which are rights of first refusal to purchase crude oil from certain third-party producers at predetermined prices.  LLC and LP also seek damages from BP for continuing to exercise the calls in denial of LLC and LP’s alleged rights to do so.  BP filed a motion to compel arbitration of the dispute, which was denied by the trial court.  The parties do not contest that the arbitration issue in this case arises under the Federal Arbitration Act[2] (the “FAA”) rather than the Texas Arbitration Act[3] and, thus, that the trial court’s ruling is reviewable by mandamus[4] rather than interlocutory appeal.[5]

                                                            Standard of Review

            A party seeking to compel arbitration by mandamus must establish both the existence of an arbitration agreement subject to the FAA and that the claims at issue fall within the scope of the arbitration agreement. In re J.D. Edwards World Solutions Co., 87 S.W.3d 546, 549 (Tex. 2002) (orig. proceeding).  If the arbitration agreement encompasses those claims and there are no defenses to enforcement of the arbitration obligation, the court has no discretion but to compel arbitration and stay its own proceedings.  Id.  Where a trial court erroneously denies a motion to compel arbitration under the FAA, the movant has no adequate remedy at law and is entitled to mandamus relief.  In re FirstMerit Bank, N.A., 52 S.W.3d 749, 753 (Tex. 2001) (orig. proceeding).

            When a party asserts a right to arbitrate under the FAA, the question whether the dispute is subject to arbitration is determined under federal law.  Prudential Secs. Inc. v. Marshall, 909 S.W.2d 896, 899 (Tex. 1995) (orig. proceeding).  As a matter of federal law, any doubts concerning the scope of arbitrable issues are resolved in favor of arbitration, whether pertaining to the construction of the contract or a defense to arbitration, such as waiver.  In re Serv. Corp. Int’l, 85 S.W.3d 171, 174 (Tex. 2002) (orig. proceeding).

                                           Existence of an Arbitration Agreement

            In 1997, LLC and LP[6] were created by BP and Shell Oil Company and its affiliates (collectively, “Shell”) pursuant to a master agreement.  An assignment agreement (the “assignment”) was also entered into whereby BP conveyed various oil and gas related assets to LP, allegedly including the calls.  BP and Shell thereafter sold a controlling interest in LLC and LP to Occidental Petroleum Corporation (“OPC”).  The agreements evidencing this sale included a purchase and sale agreement (the “PSA”) and a closing agreement.  Article 16.1 of the PSA contains the arbitration provision (the “arbitration provision”) upon which BP relies in this proceeding.  However, because LLC and LP were not parties to the PSA, our first issue is whether LLC and LP are nevertheless bound by the arbitration provision, i.e., whether an arbitration agreement exists between these parties.

            Although LLC and LP were not parties to the PSA, they were parties to the closing agreement (as was BP).  The closing agreement: (1) recites that it is “expressly contemplated by” the PSA; (2) refers to various provisions of the PSA, which contemplate certain releases, amendments and terminations of various existing agreements, and assumption of certain liabilities; (3) sets forth the terms necessary to effect those changes; and (4) contains the following merger provision (the “merger provision”): “This Agreement, together with the [PSA] and the other Operative Documents [defined in the PSA] supersede all prior . . . agreements . . . between the Parties with respect to the subject matter hereof and constitute the entire understanding and agreement between the Parties with respect thereto.”

           

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Cite This Page — Counsel Stack

Bluebook (online)
in Re: BP America Production F/K/A Amoco Production Company and Toc-Rocky Mountains, Inc, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-bp-america-production-fka-amoco-production-c-texapp-2003.