in Re Discovery Operating, Inc.

Procedural entryThis page is a short order in in Re Discovery Operating, Inc.. Read the opinion of the Court — 2007 Tex. App. LEXIS 1245
Court of Appeals of Texas·Decided February 15, 2007·No. 11-06-00301-CV·Published

Opinion

Opinion filed February 15, 2007

Opinion filed February 15, 2007

                                                                        In The

    Eleventh Court of Appeals

                                                                 ____________

                                                          No. 11-06-00301-CV

                                                    __________

                              IN RE DISCOVERY OPERATING, INC.

                                                Original Mandamus Proceeding

                                                                   O P I N I O N

Discovery Operating, Inc. filed suit against BP America Production Company for damages arising from BP=s use of two saltwater injection wells in the vicinity of Discovery=s oil and gas lease. Discovery asserted claims for negligence, negligence per se, and common law and statutory waste.[1]  Discovery alleged that BP had violated its injection-well permits and the rules and regulations of the Texas Railroad Commission.  The district court abated the proceedings until such time as the Texas Railroad Commission determines whether BP violated any commission rules, regulations, or permits.  The Railroad Commission, having previously refused BP=s request for a hearing because there was no live complaint pending with the Railroad Commission, agreed to consider the matter upon referral by the district court.  Discovery has filed a petition for writ of mandamus in our court requesting that the order of abatement be vacated and the referral to the Railroad Commission be withdrawn.  We conditionally grant the petition for writ of mandamus. 


Mandamus is an extraordinary remedy that is available to correct a clear abuse of discretion or the violation of a duty imposed by law when there is no adequate remedy by appeal.  Walker v. Packer, 827 S.W.2d 833, 839-40 (Tex. 1992) (orig. proceeding).  A trial court has no discretion in determining what the law is or in applying the law to the facts.  Id. at 840; see also In re D. Wilson Constr. Co., 196 S.W.3d 774, 780-81 (Tex. 2006). 

Discovery contends that the trial court erred in finding that the Railroad Commission had exclusive or primary jurisdiction over the matters involved in this case and that the trial court had no discretion to abate the proceedings.  Discovery relies in large part on Sections 85.321 and 85.322 of the Texas Natural Resources Code.  Tex. Nat. Res. Code Ann. '' 85.321-.322 (Vernon 2001).  These sections provide as follows: 

' 85.321.  Suit for Damages

A party who owns an interest in property or production that may be damaged by another party violating the provisions of this chapter that were formerly a part of Chapter 26, Acts of the 42nd Legislature, 1st Called Session, 1931, as amended, or another law of this state prohibiting waste or a valid rule or order of the [railroad] commission may sue for and recover damages and have any other relief to which he may be entitled at law or in equity.  Provided, however, that in any action brought under this section or otherwise, alleging waste to have been caused by an act or omission of a lease owner or operator, it shall be a defense that the lease owner or operator was acting as a reasonably prudent operator would act under the same or similar facts and circumstances.

' 85.322.  Proceedings Not to Impair Suit for Damages

None of the provisions of this chapter that were formerly a part of Chapter 26, Acts of the 42nd Legislature, 1st Called Session, 1931, as amended, no suit by or against the [railroad] commission, and no penalties imposed on or claimed against any party violating a law, rule, or order of the commission shall impair or abridge or delay a cause of action for damages or other relief that an owner of land or a producer of oil or gas, or any other party at interest, may have or assert against any party violating any rule or order of the commission or any judgment under this chapter.


BP contends that mandamus is improper because the Railroad Commission has either exclusive or primary jurisdiction over issues involving underground injection.  BP asserts that the Railroad Commission=s exclusive or primary jurisdiction stems from the Federal Safe Drinking Water Act, 42 U.S.C. '' 300f-300j; from the Texas Legislature=s designation of the Railroad Commission as the agency responsible for underground injection control; and from precedent from the Texas Supreme Court. 

Texas district courts are courts of general jurisdiction, and a constitutional presumption exists that a district court has subject matter jurisdiction absent a showing to the contrary.  See In re Entergy Corp., 142 S.W.3d 316, 322 (Tex. 2004); Subaru of Am., Inc. v. David McDavid Nissan, Inc., 84 S.W.3d 212, 220 (Tex. 2002).  Conversely, there is no presumption that administrative agencies, such as the Railroad Commission, are authorized to resolve disputes.  Agencies may exercise only those powers that have been clearly and expressly conferred by law.  David McDavid Nissan, 84 S.W.3d at 220.  Neither an agency nor a court may grant additional authority or excess power to an agency.  Id.  Furthermore, whether an agency has exclusive or primary jurisdiction is a question of law to be reviewed de novo.

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