John Leonetti v. SWN Production Company and Equinor USA Onshore Properties Inc.

CourtDistrict Court, N.D. West Virginia
DecidedJune 18, 2026
Docket5:22-cv-00035
StatusUnknown

This text of John Leonetti v. SWN Production Company and Equinor USA Onshore Properties Inc. (John Leonetti v. SWN Production Company and Equinor USA Onshore Properties Inc.) is published on Counsel Stack Legal Research, covering District Court, N.D. West Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
John Leonetti v. SWN Production Company and Equinor USA Onshore Properties Inc., (N.D.W. Va. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF WEST VIRGINIA Wheeling

JOHN LEONETTI, Plaintiff, V. CIV. ACT. NO. 5:22-CV-35 Judge Bailey SWN PRODUCTION COMPANY, and EQUINOR USA ONSHORE PROPERTIES INC., Defendants.

ORDER Pending before this Court is Defendants’ Motion for Partial Dismissal [Doc. 129] and Memorandum in Support [Doc. 130], filed May 27, 2026, in which defendants seek dismissal of plaintiff's claims for fraud, conversion, and declaratory judgment as asserted within the Amended Complaint. On June 9, 2026, plaintiff filed his Response. ‘[Doc. 138]. On June 16, 2026, defendants filed their Reply. [Doc. 145]. The Motion is now ripe for adjudication. For the reasons that follow, the Motion will be GRANTED IN PART and DENIED IN PART. BACKGROUND This case arises out of a dispute over royalty payments made pursuant to a certain oil and gas lease held by plaintiff (hereinafter, the “Subject Lease”). Defendants are the successors-in-interest to the original lessee. Plaintiff's Amended Complaint, filed under seal, generally alleges that defendants have breached said lease “through the retention

and deduction of post-production costs from the royalty share and in their failure to properly and accurately account for the total volumes and sales records for ail of the ‘oil, gas and constituents thereof’ produced from the Leonetti property, as well as its failure to pay the appropriate market values under the lease.” [Doc. 199 at f 35]. This Court recently granted plaintiff leave to amend his Complaint in order to assert his claim for fraud with more particularity and to conform his pleading to the evidence produced in discovery. See [Doc. 118]. Specifically, the Amended Complaint includes new allegations concerning affiliate sales agreements that defendants allegedly utilized to disguise and conceal post-production costs which plaintiff contends were wrongfully taken from his royalty share. See e.g., [Doc. 199 at J] 22-24 (SEALED)]. In other words, plaintiff asserts that the monies received by defendants from the sale of the oil, gas, and constituents to defendants’ affiliates would account for certain midstream expenses incurred by these affiliates in bringing the oil and gas to market, but these deducted costs would ultimately not show up.on plaintiff's royalty statements. [Id. at J 23]. In plaintiff's words: :

23. Previously unknown and undisclosed to the Plaintiff, discovery in this case has revealed that Defendants ... have entered into affiliate sales agreements which expressly provide for their affiliates to buy oil, natural gas and constitutents, including NGLs' from the Defendants at a price that provides for the express or implicit deductions of post production costs, including, but not limited to, such costs or volumes charged by

“NGLs” stands for “Natural Gas Liquids.”

the affiliates and/or third-party midstream “partners” ... in processing and transporting the oil, gas or its constituents and in separating the NGLs from the wet gas. The affiliate sales agreements and related documents either expressly allow for these deductions of post-production costs or include such costs under the name of marketing costs, marketing fees, or administrative fees. wie

24. Consistent with such affiliate sales agreements, discovery has revealed that the oil, gas, and NGLs produced and allocated to the Leonetti Wells incur allocated post-production costs in the form of volumetric reductions and fees. Certain fees are standalone charges and other fees are embedded as reductions to or netted against the gross price for oil, gas, or NGLs. Other than small NEGFLU addbacks, the field fuel use, plant fuel use, gas ‘transportation fuel, gas pipeline transportation Capacity demand fees, gas pipeline commodity fees and NGL fractionation and rail transportation fees are not disclosed on the Plaintiffs monthly revenue statements. [Id. at J] 23-24 (emphasis added)]. Essentially, therefore, the Amended Complaint alleges that defendants have wrongfully deducted post-production costs from plaintiff's earnings and wrongfully calculated his royalty share by utilizing third-party sales that are not true arms-length transactions; accordingly, the proportionate share of proceeds received by plaintiff are not reflective of the actual market price of the oil and gas products. [Id.]. While the Amended

Complaint does not specifically delineate the causes of action it asserts, plaintiff appears to assert claims for (1) breach of contract; (2) fraud/fraudulent concealment; (3) conversion; (4) declaratory judgment; and (5) punitive damages. See [id. at J 34, 38, 40-41, 45, 49, 52]. Defendants now bring the instant Motion seeking to dismiss plaintiff's claims for fraud, conversion, declaratory judgment, and punitive damages for failure to state □ claim upon which relief can be granted. [Doc. 129 at 1]; see also Fed. R. Civ. P. 12(b)(6). More specifically, defendants first contend that plaintiff's claims for fraud and conversion are barred under West Virginia’s “gist of the action” doctrine, which generally precludes parties from asserting tort claims which are duplicative of a breach of contract claim. [Doc. 130 at 1-2]. Next, defendants assert that plaintiff's declaratory judgment claim is an “improper tack-on claim” and should be dismissed as this claim is based upon the same conduct which underlies plaintiff's breach of contract claim. [Id. at 2]. Third and finally, defendants argue that, because plaintiff's tort claims are barred by the gist of the action doctrine, then, by extension, plaintiff is barred from asserting a claim for punitive damages because this type of damages is generally not recoverable in an action for breach of contract. [Id.]. STANDARD OF REVIEW A complaint must be dismissed if it does not allege “enough facts to state a claim to relief that is plausible on its face.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007); see also Giarratano v. Johnson, 521 F.3d 298, 302 (4th Cir. 2008) (applying the Twombly standard and emphasizing the necessity of plausibility). When reviewing a

motion to dismiss pursuant to Rule 12(b)(6) of the Federal Rules of Civil Procedure, the Court must assume all of the allegations to be true, must resolve all doubts and inferences in favor of the plaintiff, and must view the allegations in a light most favorable to the plaintiff. Edwards v. City of Goldsboro, 178 F.3d 231, 243-44 (4th Cir. 1999). When rendering its decision, the Court should consider only the allegations contained in the Complaint, the exhibits to the Complaint, matters of public record, and other similar materials that are subject to judicial notice. Anheuser-Busch, Inc. v. Schmoke, 63 F.3d 1305, 1312 (4th Cir. 1995) (cert. granted, Anheuser-Busch, Inc. v. Schmoke, 517 U.S. 1206 (1996)). In Twombly, the Supreme Court noted that “a plaintiff's obligation to provide the ‘grounds ' of his ‘entitle[ment] to relief’ requires more than labels and conclusions, and a formulaic recitation of the elements of a cause of action will notdo...” Twombly, 550 U.S. at 555, 570 (upholding the dismissal of a complaint where the plaintiffs did not “nudge[ ] their claims across the line from conceivable to plausible.”).

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John Leonetti v. SWN Production Company and Equinor USA Onshore Properties Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/john-leonetti-v-swn-production-company-and-equinor-usa-onshore-properties-wvnd-2026.