Lloyd Michael Hamilton v. ConocoPhillips Co. and Burlington Resources Oil & Gas Co. LP

CourtCourt of Appeals of Texas
DecidedFebruary 8, 2024
Docket13-22-00096-CV
StatusPublished

This text of Lloyd Michael Hamilton v. ConocoPhillips Co. and Burlington Resources Oil & Gas Co. LP (Lloyd Michael Hamilton v. ConocoPhillips Co. and Burlington Resources Oil & Gas Co. LP) 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
Lloyd Michael Hamilton v. ConocoPhillips Co. and Burlington Resources Oil & Gas Co. LP, (Tex. Ct. App. 2024).

Opinion

NUMBER 13-22-00096-CV

COURT OF APPEALS

THIRTEENTH DISTRICT OF TEXAS

CORPUS CHRISTI – EDINBURG

LLOYD MICHAEL HAMILTON, Appellant,

v.

CONOCOPHILLIPS CO. AND BURLINGTON RESOURCES OIL AND GAS CO. LP, Appellees.

On appeal from the 267th District Court of DeWitt County, Texas.

MEMORANDUM OPINION

Before Chief Justice Contreras and Justices Longoria and Silva Memorandum Opinion by Justice Longoria

Appellant Lloyd Michael Hamilton appeals from the trial court’s entering of a partial

take-nothing judgment against him in favor of appellees ConocoPhillips Co.

(ConocoPhillips) and Burlington Resources Oil & Gas Co. LP. (Burlington). By two issues, appellant argues: (1) he did not consent as a matter of law to appellees’ use of his surface

estate for a horizontal well project, and (2) the trial court erred by granting appellees’

nonsuit of its claims without prejudice after a jury trial. We affirm in part and reverse and

render in part.

I. BACKGROUND

Appellant’s father, Graves Graham Hamilton, died in 2004, leaving behind his wife

Mary Ellen Hamilton, appellant, and appellant’s three siblings. Graves’s will provided for

the disposition of his approximately 2,000-acre ranch (Hamilton Ranch) between Mary

Ellen, appellant, and the three siblings. Specifically, Graves’s will divided and distributed

a 954-acre portion of the Hamilton Ranch into five parts and distributed the parcels to

appellant, to Mary Ellen, and in trust to appellant’s three siblings, respectively. The will

provided that the remaining acreage would be distributed in undivided interests to

appellant, Mary Ellen, and the siblings’ three trusts.

In 2007, appellant, Mary Ellen, the siblings, and other family members entered into

an oil and gas lease covering the Hamilton Ranch and surrounding land. The lease was

later assigned to Burlington. In 2019, Burlington and the landowners, including appellant,

entered into a production sharing agreement.

In 2020, after litigation was brought by Mary Ellen to partition the ranch properties,

the family members agreed to a surface partition. A mediated settlement agreement was

signed in May 2020, a family settlement agreement was signed and dated in July 2020,

and an agreed final judgment was rendered on August 11, 2020. Finally, the partition was

recorded in the DeWitt County property records on December 8, 2020.

2 In July 2020, Burlington staked out boundaries of a proposed well pad. Appellant

objected to the location, stating that he had seen jaguarundis—an endangered cat

species thought to be extinct in Texas—in the area. Appellant suggested a different

location for the pad. Burlington relocated its pad to a different location than the one

suggested by appellant because the selected location had already been mostly cleared

and construction would pose less of a threat to any possible jaguarundis. The new pad

site encompassed four live oak and pecan trees and required construction of a road, and

therefore, on August 25, 2020, Burlington entered into a surface use agreement with Mary

Ellen prior to clearing the pad site. Burlington then secured the permits entitling it to drill

horizontal sharing wells.

Appellant filed suit against Burlington and its parent company ConocoPhillips in

September 2020, and he secured a temporary injunction based on the accommodation

doctrine, citing the alleged presence of jaguarundis. See Getty Oil Co. v. Jones, 470

S.W.2d 618, 622 (Tex. 1971) (setting forth the accommodation doctrine, which provides

that “where there is an existing use by the surface owner which would otherwise be

precluded or impaired, and where under the established practices in the industry there

are alternatives available to the lessee whereby the minerals can be recovered, the rules

of reasonable usage of the surface may require the adoption of an alternative by the

lessee”). Appellant later amended his petition to expand his claims, alleging, in addition

to the accommodation doctrine, that there was (1) breach of the lease and production

sharing agreements for failure to obtain appellant’s consent before constructing the pad

site, (2) trespass for failure to obtain appellant’s consent, and (3) breach of the lease for

3 excessive surface use. Appellant also sought declaratory judgment invalidating the

surface use agreement between Burlington and Mary Ellen. Appellant did not just

complain about the location of the pad site, but also the planned use for the site for “off-

premises production.” Burlington answered and counterclaimed for (1) breach of contract

for appellant’s interference with its water permit application, (2) breach of contract based

on appellant’s interference with the use of the property, and (3) wrongful injunction.

A. Trial Court Rulings

During a pre-trial hearing, the trial court was asked by both sides to interpret the

production sharing agreement as a matter of law. Burlington argued that the production

sharing agreement gave it the right to place the pad on appellant’s property, thus

rendering the surface use agreement with Mary Ellen moot. In contrast, appellant argued

that the production sharing agreement was drafted to calculate the royalties payable on

oil and gas and that a separate surface use agreement was necessary to allow Burlington

to conduct the proposed drilling activities, including the construction of the drilling pad.

Both sides agreed that the trial court’s ruling on the effect of the production sharing

agreement could render certain claims moot for trial. The trial court allowed the parties to

brief the issue, among others, after the conclusion of the lengthy hearing.

The trial court ultimately granted Burlington’s request to construe the lease and

production sharing agreement as granting Burlington the right to conduct off-lease

production by creating a sharing well. Effectively, the trial court’s pre-trial ruling narrowed

the scope of the jury trial to appellant’s claim regarding the accommodation doctrine.

A jury trial was held and at the close of evidence, the jury rendered a unanimous

4 verdict in favor of Burlington, rejecting appellant’s claim for breach of the accommodation

doctrine. The trial court then signed a judgment in Burlington’s favor, ordering that

appellant take nothing on his claims, denying appellant’s request for declaratory judgment

and permanent injunction, dissolving the temporary injunction, and instructing the parties

to confer on a schedule for a hearing on damages related to Burlington’s counterclaim.

Burlington subsequently nonsuited its counterclaim “without prejudice,” and the trial court

rendered an order granting the nonsuit, resulting in a final judgment. This appeal

followed. 1

II. PRE-TRIAL RULINGS

By his first issue, appellant argues that the trial court erred by: (1) denying his claim

for a declaratory judgment that the surface use agreement between Mary Ellen and

Burlington was invalid; and (2) refusing to submit jury questions on liability and damages

for breach of the lease, breach of the production sharing agreement, and trespass.

A. Standard of Review

Texas Rule of Civil Procedure 166(g) provides that a court may hold a pre-trial

hearing to identify “legal matters to be ruled on or decided by the court.” TEX. R. CIV. P.

166(g).

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Lloyd Michael Hamilton v. ConocoPhillips Co. and Burlington Resources Oil & Gas Co. LP, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lloyd-michael-hamilton-v-conocophillips-co-and-burlington-resources-oil-texapp-2024.