In Re: Texas Petroleum Investment Company

CourtDistrict Court, E.D. Louisiana
DecidedSeptember 6, 2024
Docket2:23-cv-01931
StatusUnknown

This text of In Re: Texas Petroleum Investment Company (In Re: Texas Petroleum Investment Company) is published on Counsel Stack Legal Research, covering District Court, E.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In Re: Texas Petroleum Investment Company, (E.D. La. 2024).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA

IN THE MATTER OF THE COMPLAINT * CIVIL ACTION NO. 23-1931 OF TEXAS PETROLEUM * INVESTMENT COMPANY AS OWNER * SECTION: “A”(3) OF THE VESSEL LA 5580 FF AND * VESSEL LA 5910 FN IN A CAUSE FOR * JUDGE JAY C. ZAINEY EXONERATION FROM OR * LIMITATION OF LIABILITY * MAGISTRATE JUDGE EVA J. DOSSIER * *

ORDER AND REASONS

The following motions are before the Court: Motion for Summary Judgment (Rec. Doc. 41) filed by Claimant, James Pierre, Jr.; Motion for Summary Judgment (Rec. Doc. 35), filed by Petitioner, QBE International Markets and Texas Petroleum Investment Company (“TPIC”); and Motion for Summary Judgment (Rec. Doc. 42), filed by Defendant, Clayton Wyatt Hall. Petitioner, TPIC, opposes Pierre’s motion (Rec. Doc. 41). Pierre opposes each of TPIC’s and Hall’s motions (Rec. Docs. 35 and 42). The motions, submitted for consideration on August 7, 2024, are before the Court on the briefs without oral argument. For the reasons that follow, all three motions for summary judgment are DENIED. I. Background This case arises out of a collision of two vessels, both owned by TPIC, in the inland waters of Plaquemines Parish, Louisiana, on October 10, 2022. At the time of the accident, Pierre was an employee of Eagle Services, LLC (“Eagle”), serving as a contract hand for TPIC. (Rec. Docs. 35-6, 35-7). On the day of the accident, Clayton Hall, a TPIC employee, traveled to Well No. 23 to conduct maintenance work due to its malfunction. (Deposition of James Pierre, Jr., Rec. Doc. 35-5, 29:22-25).1 Because Well No. 23 ran into the same pipeline as Well No. 64, Hall dispatched Pierre to stop the flow in Well No. 64. (Id. at 43:15-25). Once Pierre cut the flow, he was to remain there until instructed to reopen the flow. (Id. at 45:7-13). However, Pierre’s phone battery died and, after waiting fifteen minutes, he boated back to Well No. 23 to wait with Hall. (Id. at 45:14-46:3). On his way back, Pierre turned into a canal as Hall boated in his direction

and the two boats collided, injuring Pierre. (Id. at 56:7-9). Following the collision and Pierre’s injuries, Pierre filed suit in state court in Plaquemines Parish. In response, TPIC filed a Limitation of Liability proceeding in this Court on June 7, 2023 (Rec. Doc. 1). Pierre filed an answer and a claim in the limitation on September 6, 2023, and amended on March 8, 2024, adding two new parties. (Rec. Doc. 17). All parties have now separately moved for summary judgment. Pierre has moved for summary judgment on the basis that TPIC has no right to claim limitation of liability due to the Limitation of Liability Act’s newest amendments, which, he argues, exclude this accident from the scope of the statute. TPIC has moved for summary judgment on the issue of the borrowed employee doctrine, which,

if applicable, would cloak TPIC in tort immunity. Hall has, in essence, joined in this motion with his motion for summary judgment, asserting that co-employees are shielded under the borrowed employee doctrine. The Court first considers Pierre’s motion because if the statute for limitation of liability does not apply, all other motions for summary judgment are moot. II. Legal Standard Summary judgment is proper where there is “no genuine dispute of material fact” and “the movant is entitled to judgment as a matter of law.” FED. R. CIV. P. 56(a). That is, it is appropriate where “the pleadings, depositions, answers to interrogatories, and admissions on file, together with

1 All deposition citations refer to the page numbers of the depositions themselves, not to the page numbers in the CM/ECF headers. the affidavits, if any,” when viewed in the light most favorable to the non-movant, “show that there is no genuine issue as to any material fact.” TIG Ins. Co. v. Sedgwick James, 276 F.3d 754, 759 (5th Cir. 2002) (citing Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 249-50 (1986)). A dispute about a material fact is “genuine” if the evidence is such that a reasonable jury could return a verdict for the non-moving party. Id. (citing Anderson, 477 U.S. at 248). The court must draw all

justifiable inferences in favor of the non-moving party. Id. (citing Anderson, 477 U.S. at 255). Once the moving party has initially shown “that there is an absence of evidence to support the non- moving party’s cause,” Celotex Corp. v. Catrett, 477 U.S. 317, 325 (1986), the non-movant must come forward with “specific facts” showing a genuine factual issue for trial. Id. (citing Fed. R. Civ. P. 56(e); Matsushita Elec. Indus. Co. v. Zenith Radio, 475 U.S. 574, 587 (1986)). Conclusional allegations and denials, speculation, improbable inferences, unsubstantiated assertions, and legalistic argumentation do not adequately substitute for specific facts showing a genuine issue for trial. Id. (citing SEC v. Recile, 10 F.3d 1093, 1097 (5th Cir. 1993)). When faced with a well-supported motion for summary judgment, Rule 56 places the

burden on the non-movant to designate the specific facts in the record that create genuine issues precluding summary judgment. Jones v. Sheehan, Young, & Culp, P.C., 82 F.3d 1334, 1338 (5th Cir. 1996). The district court has no duty to survey the entire record in search of evidence to support a non-movant's position. Id. (citing Forsyth v. Barr, 19 F.3d 1527, 1537 (5th Cir. 1992); Nissho- Iwai Am. Corp. v. Kline, 845 F.2d 1300, 1307 (5th Cir. 1988)). III. Discussion 1. Applicability of the Limitation Statute Pierre’s motion for summary judgment relies on the Limitation of Liability Act’s newest amendments, asserting that the vessels qualify as covered small passenger vessels and therefore are excluded from the limitation of liability statute. The statute provides that it “applies to seagoing vessels and vessels used on lakes or rivers or in inland navigation, including canal boats.” 46 U.S.C. § 30502(a). However, under the amendments, the chapter does not apply to “covered small passenger vessels.” Id. (b). A covered small passenger vessel has two definitions, only one of which applies here.2 This definition states that covered vessel “means a small

passenger vessel, as defined in section 2101, that is (i) not a wing-in ground craft; and (ii) carrying (I) not more than 49 passengers on an overnight domestic voyage; and (II) not more than 150 passengers on any voyage that is not an overnight domestic voyage. 46 U.S.C. § 30501(1)(A) (cleaned up). Pierre’s motion stops at this point before providing a lengthy analysis of the retroactive application of the amendments. However, he fails to provide the definition for small passenger vessels as defined in section 2101.

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In Re: Texas Petroleum Investment Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-texas-petroleum-investment-company-laed-2024.