In re Tennessee Gas Pipeline Company Litigation

CourtDistrict Court, M.D. Tennessee
DecidedMay 6, 2025
Docket3:24-cv-00469
StatusUnknown

This text of In re Tennessee Gas Pipeline Company Litigation (In re Tennessee Gas Pipeline Company Litigation) is published on Counsel Stack Legal Research, covering District Court, M.D. Tennessee primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re Tennessee Gas Pipeline Company Litigation, (M.D. Tenn. 2025).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF TENNESSEE NASHVILLE DIVISION

IN RE TENNESSEE GAS PIPELINE ) Case No. 3:24-cv-00469 COMPANY LITIGATION ) ) Case No. 3:24-cv-00476 ) Case No. 3:24-cv-00478 ) Case No. 3:24-cv-00479 ) Case No. 3:24-cv-00483

MEMORANDUM OPINION AND ORDER

Plaintiff’s Motion for Partial Summary Judgment (Doc. No. 105) and Plaintiff’s Motion for Injunctive Relief Authorizing Immediate Possession (Doc. No. 110) are ripe for decision without any opposition. Both motions are GRANTED. To provide context and background, this is an eminent domain action under § 717f(h) of the Natural Gas Act (the “NGA”), 15 U.S.C. § 717f (2012), and Rule 71.1 of the Federal Rules of Civil Procedure. Tennessee Gas Pipeline Company, L.L.C. (“TGP”) is an interstate natural gas transmission company that has received a Certificate of Public Convenience and Necessity from the Federal Energy Regulatory Commission (“FERC”) authorizing the construction of approximately 32 miles of a 30-inch diameter interstate natural gas pipeline and related facilities in Tennessee known as the Cumberland Project. (“Certificate”). The heirs of Ms. Callie Vanleer (“Landowners”) claim an interest in a parcel of land located in Dickson County, Tennessee that is approximately 100 acres in size (the “Subject Property”). TGP filed this action to condemn a temporary and permanent easement in the Subject Property. The Landowners can be divided into three groups: (1) those what have agreed that TGP may condemn the easements and have granted TGP possession of these easements; (2) those that appeared in this matter but have not objected to TGP’s right to condemn; and (3) those who have been served but not appeared in this matter. The pending Motions relate to the latter two groups of Landowners. One Landowner, Donald L. Mixon, sent a letter to the Court in response to Plaintiff’s Motion for Partial Summary Judgement (Doc. No. 108). No other Landowners have filed any

response to Plaintiff’s pending Motions. Mr. Mixon’s letter did not dispute any material fact raised in TGP’s Statement of Undisputed Material Facts, which the Court finds are undisputed. Plaintiff’s Motion for Partial Summary Judgment seeks judicial confirmation of TGP’s substantive right to condemn the property rights that are the subject matter of this lawsuit pursuant to §717f(h) of the Natural Gas Act (“NGA”). Nexus Gas Transmission, LLC v. City of Green, 757 F. App’x 489, 492 n.2 (6th Cir. 2018) (citing E. Tenn. Natural Gas Co. v. Sage, 361 F.3d 808, 831 (4th Cir. 2004)). The NGA permits a holder of a certificate of public convenience and necessity to condemn the necessary property interests if it is unable to reach an agreement with the landowner: When any holder of a [Certificate] cannot acquire by contract, or is unable to agree with the owner of the property to the compensation to be paid for the necessary right-of-way to construct, operate, and maintain a pipe line or pipe lines for the transportation of natural gas, and the necessary land or other property, in addition to right-of- way, . . . it may acquire the same by the exercise of the right of eminent domain in the district court of the United States for the district in which such property may be located, or in the State courts.

15 USC § 717f(h); see also Sage, 361 F.3d at 818. Thus, to condemn property TGP must show (1) that it holds a certificate of public convenience and necessity; (2) that the land to be taken is necessary to the project; and (3) that it and the landowner were unable to agree on a price for the taking. 15 U.S.C. § 717f; see Nexus Gas, 757 F. App’x at 493. TGP satisfies each requirement. First, it is undisputed that TGP holds a certificate of public convenience and necessity from FERC. Compl., Ex. C. (Doc. Nos. 1 and 1-3). Second, it is undisputed that the property interests are necessary to the project. It is well settled that “by issuing the Certificate of Public Convenience and Necessity under the Natural Gas Act, FERC has already determined that Defendants’ property interests are necessary.” Gas Transmission Nw., LLC v. 15.83 Acres of Permanent Easement More or Less, located in Morrow

Cnty., 126 F. Supp. 3d 1192, 1197 (D. Or. 2015) (quoting Williston Basin Interstate Pipeline Co. v. Prop. Ints. Necessary to Conduct Gas Storage Operations in Subterranean Geological Formations on & Beneath Props. Located in Twp. 9 S., Range 23 E., Section 34, 35 & 36, No. CV–09–167–BLG–RFC, 2010 WL 5104991, at *2 (D. Mont. Dec. 9, 2010)). This Court need not inquire into the necessity of acquiring this tract as it is in the path expressly determined necessary by FERC. (Doc. No. 111-1 at 19–20, Bowers Dec., Ex. A and B.). Third, there is also no dispute that TGP has been unable to acquire the necessary property interests from these landowners. Had TGP been able to do so, it certainly would not have filed this condemnation action. This fact is also supported by the undisputed declaration of David Bowers. (Doc. No. 111-1). The Bowers’ declaration establishes TGP’s good faith negotiations,

regardless of whether there is such a requirement in the statute. Sabal Trail Transmission, LLC v. 7.72 Acres in Lee Cnty., Ala., No. 3:16-CV-173-WKW, 2016 WL 8900100, at *8 (M.D. Ala. June 3, 2016), report and recommendation adopted, No. 3:16-CV-173-WKW, 2016 WL 3450827 (M.D. Ala. June 20, 2016); E. Tenn. Nat. Gas, LLC v. 3.62 Acres in Tazewell Cnty. Va., No. CIV.A. 1:06- CV00028-29, 2006 WL 1453937, at *10 (W.D. Va. May 18, 2006) (“[N]othing in the Act or Federal Rule of Civil Procedure 71[.1] requires the condemnor to negotiate in good faith. All the Act requires is a showing that the plaintiff has been unable to acquire the property by contract or has been unable to agree with the owner of the property as to the compensation to be paid.”); E. Tenn. Nat. Gas, LLC v. 1.28 Acres in Smyth Cnty. Va., Nos. Civ.A. 06-CV-00022, 00028–29, 00036–37, 00044, 2006 WL 1133874, *10 (W.D. Va. Apr. 26, 2006) (same); Kan. Pipeline Co. v. 200 Foot by 250 Foot Piece of Land, Located in Section 6, Sw. Quarter, Twp. 32 S., Range 10 W., Cnty. of Barber, State of Kan., 210 F. Supp. 2d 1253, 1257 (D. Kan. 2002) (holding that good faith negotiations are not required for condemnation).

TGP has complied with all the conditions of the delegation of the power to condemn mandated by the United States, and it can lawfully exercise the power of eminent domain over the property at issue in this case. Having determined that TGP has a right to condemn the property interests at issue, the Court now turns to TGP’s Motion for Preliminary Injunction. TGP is entitled to equitable relief in the form of a preliminary injunction authorizing immediate possession. “A preliminary injunction is always appropriate to grant intermediate relief of the same character as that which may be granted finally.” De Beers Consol. Mines v. United States, 325 U.S. 212, 220 (1945).

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In re Tennessee Gas Pipeline Company Litigation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-tennessee-gas-pipeline-company-litigation-tnmd-2025.