in Re: Rusk Energy, Ltd.

CourtCourt of Appeals of Texas
DecidedJanuary 31, 2008
Docket12-07-00245-CV
StatusPublished

This text of in Re: Rusk Energy, Ltd. (in Re: Rusk Energy, Ltd.) 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: Rusk Energy, Ltd., (Tex. Ct. App. 2008).

Opinion

                                                NO. 12-07-00245-CV

IN THE COURT OF APPEALS

TWELFTH COURT OF APPEALS DISTRICT

TYLER, TEXAS

§                     

IN RE:

§                      ORIGINAL PROCEEDING

RUSK ENERGY, LTD.

MEMORANDUM OPINION

            Rusk Energy, Ltd. seeks a writ of mandamus requiring the trial court to vacate the portion of its December 15, 2006 order requiring a $100,000 bond from Rusk and to release the funds posted in compliance with the order back to Rusk.1  We conditionally grant the writ.

Background

            Kim R. Smith, the real party in interest, owns the surface of 79 acres of land in Rusk County, Texas.  Smith purchased the tract subject to a reservation of the minerals and an existing oil, gas, and mineral lease that does not provide for surface damages.  Rusk is the majority working interest owner.  In early November 2006, Rusk notified Smith that it intended to drill the Gray Unit No. 2 gas well on Smith’s land.  Rusk ultimately determined that its operations would occupy two acres of Smith’s land.  In what it describes as a “gesture of good will,” Rusk offered Smith $12,500 as compensation for any damages its operations might cause to Smith’s land.  When Smith did not accept its offer, Rusk delivered a $12,500 check to Smith’s office.  Smith never cashed the check.

            By the end of November 2006, Pioneer Drilling Company, the drilling contractor, had completed the well location.  On December 12, 2006, Smith sued Pioneer seeking an ex parte temporary restraining order (TRO) as well as temporary and permanent injunctive relief to prevent Pioneer from directly or indirectly developing the well site.  Smith alleged, in part, that the 79 acre tract was “being developed for real estate and . . . that Defendant’s usage of the surface [was] excessive and unreasonable in the placement of its well and [has] rendered Plaintiff’s property virtually useless.”  Smith also alleged that Pioneer had moved its rig immediately adjacent to a dedicated city street without seeking the proper permits for a variance in constructing its well at that location.  As grounds for injunctive relief, Smith alleged that Pioneer had threatened irreparable harm to his property and rights; that Pioneer’s conduct was completely without right; and that Smith had no adequate remedy at law for the injuries and losses that had been caused by Pioneer’s conduct and would continue to be caused without injunctive relief. 

            The trial court granted the TRO and required Smith to post a $5,000 bond.  Rusk and Chalker Energy Management II, LLC, the operator of the well, intervened in the suit and filed a motion to dissolve the TRO.  After a hearing on December 15, 2006, the trial court dissolved the TRO and ordered that drilling could resume “upon the filing of a bond in the amount of $100,000.00.”  Later that day, Rusk posted a cash bond in the required amount and also filed an objection and motion for reconsideration of the trial court’s order.2  The trial court heard the motion for reconsideration on February 15, 2007, took the matter under advisement, and ordered mediation.  After a failed mediation, Rusk filed a second motion for reconsideration and again requested that the court release its cash bond.  After a hearing, the court denied Rusk’s motion by letter on June 6, 2007.  This original proceeding followed.

Prerequisites to Mandamus

            Mandamus is available to correct a clear abuse of discretion when there is no adequate remedy by appeal.  In re Prudential Ins. Co. of Am., 148 S.W.3d 124, 135-36 (Tex. 2004).  A trial court abuses its discretion if it reaches a decision so arbitrary and unreasonable as to amount to a clear and prejudicial error of law.  Walker v. Packer, 827 S.W.2d 833, 839 (Tex. 1992).  A trial court has no discretion in determining what the law is or in applying the law to the facts.  Id. at 840.  Thus, a clear failure by the trial court to analyze or apply the law correctly constitutes an abuse of discretion.  Id.  A trial court also abuses its discretion when there is no evidence to support its ruling.  Weisel Enters., Inc. v. Curry, 718 S.W.2d 56, 58 (Tex. 1986); D.N.S. v. Schottman, 937 S.W.2d 151, 155 (Tex. App.–Fort Worth 1997, orig. proceeding).

            An appellate remedy is “adequate” when any benefits to mandamus review are outweighed by the detriments.  In re Prudential, 148 S.W.3d at 136.  When the benefits to mandamus review outweigh the detriments, appellate courts must consider whether the appellate remedy is adequate.  Id.  This determination is not an abstract or formulaic one; it is practical and prudential.  Id.  Whether an appellate remedy is “adequate” so as to preclude mandamus review depends heavily on the circumstances presented and is better guided by general principles than by simple rules.  Id. at 137.  The word “adequate” is simply a proxy for the careful balance of jurisprudential considerations that determine when appellate courts will use original mandamus proceedings to review the actions of lower courts.  Id. at 136.

Preliminary Arguments

            Smith contends that we need not reach the substance of Rusk’s petition because (1) Rusk voluntarily posted the $100,000 cash bond rendering the controversy moot; (2) Rusk cannot challenge the order requiring the bond because it has accepted the benefits of it; and (3) Rusk waited seven months after the date of the order, without explanation or justification, before filing its petition for writ of mandamus.  We address each of these arguments in turn.

            Mootness. 

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