In Re Channelview Flooding Litigation v. the State of Texas

CourtCourt of Appeals of Texas
DecidedDecember 31, 2024
Docket01-22-00946-CV
StatusPublished

This text of In Re Channelview Flooding Litigation v. the State of Texas (In Re Channelview Flooding Litigation v. the State of Texas) 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 Channelview Flooding Litigation v. the State of Texas, (Tex. Ct. App. 2024).

Opinion

Opinion issued December 31, 2024

In The

Court of Appeals For The

First District of Texas ———————————— NO. 01-22-00946-CV ——————————— IN RE CHANNELVIEW FLOODING LITIGATION

On Appeal from the 190th District Court Harris County, Texas Trial Court Case No. 2022-37626

MEMORANDUM OPINION

One hundred twenty-five property owners filed lawsuits alleging that the

construction of two crude oil pipelines in a utility corridor caused their properties to

flood. The defendants—utility companies, the pipeline owners, and the pipeline

construction contractor—moved to dismiss under Section 150.002 of the Civil

Practice and Remedies Code, which requires a “certificate of merit” in “any action” for “damages arising out of the provision of professional services by a licensed or

registered professional,” including engineers.1 The multidistrict litigation (“MDL”)

court presiding over pretrial matters denied the motion to dismiss.

On appeal,2 the defendants contend:

(1) Section 150.002 required the owners to file a certificate of merit because their claims arise out of the provision of professional engineering services; and (2) The owners’ certificates of merit do not comply with the statute because they contain only collective assertions of actions, errors, and omissions that do not differentiate between defendants. Because we conclude that Chapter 150 applies and that the certificates of merit

are defective as to some but not all defendants, we reverse in part, affirm in part, and

remand.

Background

CenterPoint Energy Houston Electric, LLC (“CenterPoint Electric”) granted

an easement to Oiltanking Houston, L.P. (“the CenterPoint easement”) for the

construction of two crude oil pipelines in a utility corridor running through

Channelview, Texas. Four years after the pipelines were completed, plaintiffs Mary

Evans and Don Weston Dorrell (“the Evans parties”) filed a putative class action

1 See TEX. CIV. PRAC. & REM. CODE § 150.001(1–c), .002(a). 2 See id. § 150.002(f). 2 (“the Evans lawsuit”), claiming that the pipeline construction had caused properties

near the CenterPoint easement to flood.

The original petition in the Evans lawsuit named as defendants CenterPoint

Energy; Oiltanking Partners, LP (“Oiltanking”); and Enterprise Products Partners,

LP (“Enterprise Partners”), the then-owner of the pipeline. The petition alleged that

Oiltanking and Enterprise Partners had “excavated huge quantities of soil from the

CenterPoint easement” to create a trench large enough for the pipelines. Then, after

laying the pipeline, Oiltanking and Enterprise Partners returned the excavated soil

to the trench and compacted it. According to the Evans parties, the soil covering the

CenterPoint easement became “impermeable” and “brick-like” because, “by not

hauling in new soil to match the original topsoil composition and structure,”

Oiltanking and Enterprise Partners had compacted “hardened clay” that was

“naturally present in the subsurface layers in the area at issue” on the surface of the

CenterPoint easement. And this, in turn, caused water to run off the CenterPoint

easement onto adjacent properties.

Considering the construction “occur[red] merely feet away from hundreds of

homes and residents,” the Evans parties said, it was “reasonable to expect that

[CenterPoint Energy, Oiltanking, and Enterprise Partners3] would return the pipeline

3 The original petition the Evans lawsuit refers to these parties collectively as “Defendants.”

3 easement to a state of structural integrity which would leave neighboring properties

undisturbed.” Instead, trees began to fall, “grounds remained saturated and swampy

for days and weeks on end following rain events,” sidewalks buckled, driveways and

backyards sank, and building walls and floors cracked.

Based on these allegations and others related to information they claimed

CenterPoint Energy, Oiltanking, and Enterprise Partners did not share about the

construction, the Evans parties pleaded class claims for negligence; negligence per

se; negligent hiring, supervision, and training; gross negligence; private nuisance;

and fraud by nondisclosure. And they sought damages for the loss of use and

enjoyment of their homes, diminution of their property value, and repair costs. They

also sought exemplary damages.

Contemporaneously with their original petition, the Evans parties filed a

certificate of merit prepared by their engineering expert, M. Doyle Sanders, under

Section 150.002 of the Civil Practice and Remedies Code (“the original Sanders

certificate”). See TEX. CIV. PRAC. & REM. CODE § 150.002(a). Sanders holds a

Bachelor of Science degree in civil engineering from Texas A & M University, is a

professional engineer licensed in Texas and six other states, with 50 years’

experience, and claims specific knowledge “in the areas of pipeline design,

development, and construction.” In his first certificate of merit, Sanders said that

4 “licensed or registered professionals working for or at the direction of” Enterprise

Products, Oiltanking, “and/or” CenterPoint Energy were negligent in

• failing to adequately or appropriately design the pipeline at issue to prevent the diversion of surface water . . . into the [surrounding] neighborhoods . . . ;

• failing to develop a method of construction . . . that preserve[d] the structural integrity of soil covering the pipeline, the composition of topsoil, and the natural flow of surface water over and into [the CenterPoint easement];

• failing to mitigate damage, nuisance, and/or adverse impact as the result of the diversion of surface water into the [surrounding] neighborhoods . . . ; and

• failing to warn [the Evans parties], Class Members, and the surrounding public of the damage and adverse impact that would result from the construction of the pipeline[.] According to Sanders, the factual basis for these claims was “apparent” because,

after the pipeline was constructed, surface water was diverted away from the

CenterPoint easement onto adjacent properties.

Enterprise objected to the certificate of merit and moved to dismiss the Evans

lawsuit. The motion asserted that the Evans parties’ petition invoked Section

150.002 by alleging claims arising out of the provision of professional engineering

services. The motion also asserted that the original Sanders certificate was deficient

in that it contained only collective, non-particularized allegations of negligence that

did not differentiate between defendants and provided only vague allegations that

did not “set forth specifically for each theory of recovery” the alleged acts, errors,

5 and omissions, and their factual basis. See TEX. CIV. PRAC. & REM. CODE

§ 150.002(b). CenterPoint joined the motion.

While the motion to dismiss was pending, the Evans parties amended their

petition three times. In their first amended petition, the Evans parties named

additional defendants, including Troy Construction, the pipeline construction

contractor, and several more Enterprise and CenterPoint companies. The additional

Enterprise companies were Enterprise Houston Ship Channel, L.P. (“Enterprise Ship

Channel LP”), a company that purchased Oiltanking after construction of the

pipelines; Enterprise Houston Ship Channel GP, LLC (“Enterprise Ship Channel

GP”); Enterprise Terminaling Services GP, LLC (“Enterprise Terminaling”); and

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