Jacob Puderer v. Hilcorp Energy Company, Northcoast Oil Company and the State of Louisiana Through the Department of Natural Resources

CourtLouisiana Court of Appeal
DecidedMarch 24, 2021
Docket2020-CA-0383
StatusPublished

This text of Jacob Puderer v. Hilcorp Energy Company, Northcoast Oil Company and the State of Louisiana Through the Department of Natural Resources (Jacob Puderer v. Hilcorp Energy Company, Northcoast Oil Company and the State of Louisiana Through the Department of Natural Resources) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jacob Puderer v. Hilcorp Energy Company, Northcoast Oil Company and the State of Louisiana Through the Department of Natural Resources, (La. Ct. App. 2021).

Opinion

JACOB PUDERER * NO. 2020-CA-0383

VERSUS * COURT OF APPEAL HILCORP ENERGY * COMPANY, NORTHCOAST FOURTH CIRCUIT OIL COMPANY AND THE * STATE OF LOUISIANA STATE OF LOUISIANA THROUGH THE ******* DEPARTMENT OF NATURAL RESOURCES

APPEAL FROM 25TH JDC, PARISH OF PLAQUEMINES NO. 62-597, DIVISION “A” Honorable Kevin D. Conner, Judge ****** Judge Terri F. Love ****** (Court composed of Chief Judge James F. McKay, III, Judge Terri F. Love, Judge Edwin A. Lombard)

Christine L. DeSue ATTORNEY AT LAW 3445 N. Causeway Blvd. Suite 505 Metairie, LA 70002

COUNSEL FOR PLAINTIFF/APPELLANT

Kevin P. Merchant Phillip M. Smith NEUNERPATE One Petroleum Center, Suite 200 1001 West Pinhook Road Lafayette, LA 70503

COUNSEL FOR DEFENDANT/APPELLEE

AFFIRMED MARCH 24, 2021 TFL

JFM This is a maritime tort case. Appellant, Jacob Puderer, filed a negligence EAL suit against Appellee, Hilcorp Entergy Co. (“Hilcorp”), alleging Hilcorp was liable

to Appellant for damages resulting from an allision between Appellant’s boat and

an underwater obstruction under Hilcorp’s care, custody, and control. Hilcorp

disputed any ownership or lease interest in the allision site or control over the

underwater obstruction and filed a motion for summary judgment. Appellant

appeals the district court’s judgment granting Hilcorp’s motion for summary

judgment. Finding that Appellant failed to raise genuine issues of material fact as

to Hilcorp’s ownership, placement, or control over the underwater obstruction, we

affirm the summary judgment.

FACTUAL AND PROCEDURAL HISTORY

Mr. Puderer owned a commercial fishing boat. He authorized Eric Tiser to

operate the boat. On or around November 12, 2014, Tiser went trawling for

shrimp in appellant’s boat in Township 22-S, Range 30-E, Section 17 (“Township

22-S”) when the boat hit a submerged underwater obstruction in the late afternoon.

1 Tiser stated that the boat caught onto the unseen obstruction and that at one point,

the combination of high winds and the weight of the boat pulled the obstruction out

of the water. He stated that he was able to identify the obstruction as a wellhead

with spindles that the boat’s shrimp trawling equipment had stuck on. Tiser was

able to free the boat after two or three hours, but it flooded and eventually sank

somewhere between Tante Phine and Red Pass.

Mr. Puderer notified Hilcorp of the incident. Hilcorp sent its production

foreman, Shane Ferguson, to the allision site identified by Mr. Tiser. Ferguson met

with Tiser and “Joe,” the boat’s deckhand, about a day or two after the incident.

Based on the GPS coordinates and information provided by Tiser, Ferguson

marked the allision site with a PVC pole and completed an incident report.1

Ferguson also accompanied Mr. Puderer to the location of the sunken boat and

took photographs. On the same day, Hilcorp retained JRon Services Site Survey, a

third-party dive service company, to survey the allision site. JRon’s report

concluded that a handrail was the only object that was above the mudline at the

time of their survey which could have allided with the boat.

Mr. Puderer filed suit against Hilcorp, contending that Hilcorp was liable in

tort for damages resulting from the loss of his boat. Mr. Puderer alleged Hilcorp

held a lease in Township 22-S which encompassed the allision site and therefore,

was responsible for maintaining any wellheads and/or underwater structures on or

1 Appellant signed the incident report as the boat’s owner. Tiser and Joe “the deckhand” were listed as “witnesses” on the report.

2 around the site. Hilcorp denied the allegations. After Tiser’s deposition and the

parties exchanged discovery, Hilcorp filed a motion for summary judgment.

Hilcorp’s support for its motion for summary judgment included an affidavit

from Max Douglas Weaver, its Chief Operations Engineer (“COE”). The COE’s

affidavit attested that Hilcorp was not the owner or lessee of any of the property

Appellant identified as the allision site in his coordinates2, nor did it own, control,

place, maintain, have knowledge of, or derive any benefit from the alleged

underwater obstruction that struck Mr. Puderer boat.3

2 Appellant and Tiser presented Hilcorp with three sets of coordinates as the allision site. Ultimately, Appellant represented that the correct coordinates were N 29.10.980, W 089.790. 3 The affidavit of the COE attested, in relevant part, to the following:

3.

Hilcorp Energy Company does not hold any ownership or lease interest in any property located at any of the following coordinates: 1) N 29° 10’58.5”, W 89° 26’ 47.5”; 2) N 29.10. 989, W 089.26.790; 3) N 29.10.980, W 089.26.790.

4.

Hilcorp Energy Company did not hold any ownership or lease interest in any property located at any of the following coordinates in November 2014: 1) N 29° 10’58.5”, W 89° 26’ 47.5”, 2) N 29.10.989, W 089.26.790; 3) N 29.10.980, W 089.26.790.

5.

Hilcorp Energy Company does not own anything in the waters located at any of the following coordinates: 1) N 29° 10’58.5”, W 89° 26’ 47.5”; 2) N 29.10.989, W 089.26.790; 3) N 29.10.980, W 089.26.790.

6.

Hilcorp Energy Company does not control anything in the waters located at any of the following coordinates: 1) N 29° 10’58.5”, W 89° 26’ 47.5”; 2) N 29.10.989, W 089.26.790; 3) N 29.10.980, W 089.26.790.

7.

Hilcorp Energy Company has not placed anything in the waters located at any of the following coordinates: 1) N 29° 10’58.5”, W 89° 26’ 47.5”; 2) N 29.10.989, W 089.26.790; 3) N 29.10.980, W 089.26.790.

3 Mr. Puderer countered that a genuine issue of material fact remained as to

whether the allision site and the underwater obstruction were leased, maintained,

and/or controlled by Hilcorp. In support of this argument, Mr. Puderer attached

affidavits from Glenn Fleming, an abstractor, and his attorney, Christine L. DeSue.

Their affidavits represented that a public records search documented that the

original lease held by the Buras Levee District containing Township 22-S was

assigned to Chevron, which in turn assigned all of its leases in Township 22-S to

Hilcorp. Mr. Puderer’s individual affidavit detailed the coordinates of the allision

site and the area where his boat sank and declared, in part, that “[a]fter the

incident, Hilcorp went back to the site and cleaned up any obstructions that were

hanging up boats in the water.4”

At the hearing on Hilcorp’s summary judgment motion, questions were

raised as to whether Ferguson had identified a wellhead at the time he placed the

8.

Hilcorp Energy Company has not maintained anything in the waters located at any of the following coordinates: 1) N 29° 10’58.5”, W 89° 26’ 47.5”; 2) N 29. 10.989, W 089.26.790; 3) N 29.10.980, W 089.26.790.

9.

Hilcorp Energy Company has not received any benefit from anything in the waters located at any of the following coordinates: 1) N 29° 10’58.5”, W 89° 26’ 47.5”; 2) N 29.10.989, W 089.26.790; 3) N 29.10.980, W 089.26.790.

10.

Prior to November 12, 2014, Hilcorp Energy Company had no knowledge of and was not notified of the existence of a wellhead located underwater at any of the following coordinates: 1) N 29° 10’58.5, W 89° 26’ 47.5”; 2) N 29.10.989, W 089.26.790; 3) N 29.10.980, W 089.26.790. 4 Appellant also attested that “I personally took Shane Ferguson, a representative of Hilcorp, to the allision site the day after the incident.”

4 PVC pipe marker at the allision site. The district court held the record opened on

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Jacob Puderer v. Hilcorp Energy Company, Northcoast Oil Company and the State of Louisiana Through the Department of Natural Resources, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jacob-puderer-v-hilcorp-energy-company-northcoast-oil-company-and-the-lactapp-2021.