in Re BP Oil Supply Company

CourtCourt of Appeals of Texas
DecidedAugust 3, 2010
Docket14-10-00424-CV
StatusPublished

This text of in Re BP Oil Supply Company (in Re BP Oil Supply Company) 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 Oil Supply Company, (Tex. Ct. App. 2010).

Opinion

Petition for Writ of Mandamus Conditionally Granted and Opinion filed August 3, 2010.

In The

Fourteenth Court of Appeals

NO. 14-10-00424-CV

In Re BP Oil Supply Company, Relator

ORIGINAL PROCEEDING

WRIT OF MANDAMUS

OPINION

On May 13, 2010, relator, BP Oil Supply Company, filed a petition for writ of mandamus in this court.  See Tex. Gov’t Code Ann. §22.221 (Vernon 2004); see also Tex. R. App. P. 52.  In the petition, BP asks this court to compel the Honorable Alexandra Smoots-Hogan, presiding judge of the 164th District Court of Harris County, to set aside her order denying BP’s motion to dismiss, or in the alternative, to stay.  We conditionally grant the petition.

I

            The underlying dispute relates to a buy-sell agreement[1] between BP and the real party in interest, ConocoPhillips Company.  The agreement required BP to deliver 54,000 barrels per day of Heavy Louisiana Sweet crude oil to ConocoPhillips in Empire, Louisiana, and required ConocoPhillips to deliver 54,000 barrels per day of West Texas Intermediate crude oil to BP in Cushing, Oklahoma.  Due to Hurricanes Gustav and Ike, BP failed to deliver the required volumes of crude oil to ConocoPhillips in August and September 2008.  Instead, BP made its August and September deliveries in November 2008.  ConocoPhillips then paid the November 2008 price for the delayed deliveries, rather than the August and September 2008 prices.  BP alleges that because the market price dropped significantly between August and November 2008, ConocoPhillips’ refusal to pay the August and September 2008 prices damaged BP in the amount of more than $50 million.  ConocoPhillips, on the other hand, asserts that paying the August and September 2008 prices would have resulted in a windfall to BP.

            The parties unsuccessfully mediated their dispute before either filed suit.  At 12:02 p.m (CST), on November 4, 2009, BP filed a breach-of-contract action against ConocoPhillips in Delaware state court, seeking more than $50 million in damages.  That same day, at 5:40 p.m. (CST), ConocoPhillips filed a declaratory-judgment action in the 164th District Court in Harris County seeking a declaration that it did not breach the buy-sell agreement and asserting a claim for breach of the duty of good faith and fair dealing. 

            On November 2, ConocoPhillips moved to dismiss or, alternatively, to stay the Delaware case for forum non conveniens.  BP filed its own motion to dismiss or, alternatively, to stay the Texas case on December 7. 

            The hearing in the Delaware case took place on January 12, 2010; on February 25, the Delaware court denied ConocoPhillips’ motion to dismiss.  See BP Oil Supply Co. v. ConocoPhillips Co., C.A. No. N09C-11-028, 2010 WL 702382 (Del. Super. Feb. 25, 2010).  The Harris County trial court set BP’s motion to be heard on January 22.  However, on January 20 BP requested that the hearing be reset for February 26, and on February 23 requested that the hearing be reset again for March 26.  The trial court heard and denied BP’s motion to dismiss or, alternatively, to stay at the March 26 hearing. 

            At a scheduling conference on April 12, the Delaware court entered an order setting its case for trial on March 21, 2011.  The Texas trial court also issued a docket control order on April 12 setting its case for trial on November 1, 2010. 

II

To be entitled to the extraordinary relief of a writ of mandamus, the relator must show that the trial court abused its discretion and there is no adequate remedy by appeal.  In re Laibe Corp., 307 S.W.3d 314, 316 (Tex. 2010) (orig. proceeding) (per curiam).  A trial court abuses its discretion if it reaches a decision so arbitrary and unreasonable as to constitute a clear and prejudicial error of law, or if it clearly fails to correctly analyze or apply the law.  In re Columbia Med. Ctr. of Las Colinas, 306 S.W.3d 246, 248 (Tex. 2010) (orig. proceeding) (per curiam); In re Cerberus Capital Mgmt., L.P., 164 S.W.3d 379, 382 (Tex. 2005) (orig. proceeding) (per curiam).  In determining whether appeal is an adequate remedy, we consider whether the benefits outweigh the detriments of mandamus review.  In re BP Prods. N. Am., Inc., 244 S.W.3d 840, 845 (Tex. 2008) (orig. proceeding).

Abuse of Discretion

            BP argues that the trial court abused its discretion by denying BP’s motion because principles of comity require deference to the first-filed Delaware case and that the later-filed Texas case be stayed.  “Our federal system benefits from a measure of state-to-state comity, which, while not a constitutional obligation, is a ‘principle of mutual convenience whereby one state or jurisdiction will give effect to the laws and judicial decisions of another.’”  In re AutoNation, Inc., 228 S.W.3d 663, 670 (Tex. 2007) (orig. proceeding) (quoting Gannon v. Payne, 706 S.W.2d 304, 306 (Tex. 1986)); see also Nowell v. Nowell, 408 S.W.2d 550, 553 (Tex. Civ. App.—Dallas 1966, writ dism’d) (“Comity has frequently been defined as the recognition that one sovereignty allows within its territory to the legislative, executive, or judicial act of another sovereignty, having due regard to the rights of its own citizens.”). 

            The mere pendency of a prior suit in one state cannot be pleaded in abatement or in bar to a subsequent suit in Texas, even though both suits are between the same parties and involve the same subject matter.  In re State Farm Mut. Auto. Ins. Co., 192 S.W.3d 897, 900 (Tex. App.—Tyler 2006, orig. proceeding) (citing Evans v. Evans, 186 S.W.2d 277, 279 (Tex. Civ. App.—San Antonio 1945, no writ)); Project Eng’g USA Corp. v. Gator Hawk, Inc., 833 S.W.2d 716, 724 (Tex.

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