Louisiana Minerals Ltd v. Weyerhaeuser Co

CourtDistrict Court, W.D. Louisiana
DecidedJune 20, 2025
Docket5:22-cv-00145
StatusUnknown

This text of Louisiana Minerals Ltd v. Weyerhaeuser Co (Louisiana Minerals Ltd v. Weyerhaeuser Co) is published on Counsel Stack Legal Research, covering District Court, W.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Louisiana Minerals Ltd v. Weyerhaeuser Co, (W.D. La. 2025).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF LOUISIANA SHREVEPORT DIVISION

LOUISIANA MINERALS, LTD CIVIL ACTION NO. 22-145 VERSUS JUDGE JERRY EDWARDS, JR. WEYERHAEUSER COMPANY MAG. JUDGE MARK L. HORNSBY MEMORANDUM RULING & ORDER Louisiana Minerals, Ltd. (“LML”) filed the instant suit against Weyerhaeuser Company (“Weyerhaeuser”) asserting that Weyerhaeuser has breached a 1986 Timber Sale and Lease Contract (“Timber Lease”) by entering into unauthorized third-party agreements that impinge upon LML’s mineral rights.1 LML seeks damages for harm caused by Weyerhaeuser’s alleged breach of contract and a declaration of the parties’ rights under the Timber Lease to preclude Weyerhaeuser’s “unauthorized” activity going forward.2 The bench trial of this case is set for August 4, 2025. Before the Court is LML’s Daubert Motion or Alternative Motion in Limine to Exclude or Limit the Testimony of Certain Weyerhaeuser’s Experts (the “Hodges et

al Motion”) (R. Doc. 105). For the reasons below, this motion is GRANTED IN PART AND DENIED IN PART. LEGAL STANDARD Rule 702 of the Federal Rules of Evidence provides that “[a] witness who is

1 R. Doc. 1-1. 2 R. Doc. 1-1 at 3-4, ¶¶ 9, 10. qualified as an expert by knowledge, skill, experience, training, or education may testify in the form of an opinion or otherwise” when: (a) the expert's scientific, technical, or other specialized knowledge will help the trier of fact to understand the evidence or to determine a fact in issue; (b) the testimony is based on sufficient facts or data; (c) the testimony is the product of reliable principles and methods; and (d) the expert has reliably applied the principles and methods to the facts of the case.3 “The threshold question in determining whether an individual may offer expert testimony under Rule 702 is whether the individual possesses the requisite qualifications” to render an opinion on a particular subject matter.4 Apart from determining the qualifications of the expert, the Court must act as a “gate-keeper” to ensure that the proffered expert testimony is “both reliable and relevant.”5 The reliability prong mandates that expert opinion “be grounded in the methods and procedures of science and ... be more than unsupported speculation or subjective belief.”6 The relevance prong requires the proponent to demonstrate that the expert's “reasoning or methodology can be properly applied to the facts in issue.”7 “To qualify as an expert, the witness must have such knowledge or experience in his field or calling as to make it appear that his opinion or inference will probably aid the trier in his search for truth.”8 “Experience alone or in conjunction with other

3 FED. R. CIV. P. 702. 4 Wagoner v. Exxon Mobil Corp., 813 F. Supp. 2d 771, 798 (E.D. La. 2011). 5 Wagoner, 813 F. Supp. at 798 (citation omitted). 6 Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579, 590, 113 S.Ct. 2786, 125 L.Ed.2d 469 (1993). 509 U.S. at 590, 113 S.Ct. 2786); see also, Moore v. Ashland Chem. Inc., 151 F.3d 269, 276 (5th Cir.1998) (en banc). 7 Daubert, 509 U.S. at 592–93, 113 S.Ct. 2786. 8United States v. Hicks, 389 F.3d 514, 524 (5th Cir. 2004) (citation, alterations, and internal quotations omitted). knowledge, skill, training, or education, may provide a sufficient basis for expert testimony.”9 “An expert witness is not strictly confined to his area or practice but may testify concerning related applications” because an expert’s lack of specialization goes

to the weight rather than the admissibility of the evidence.10 Ultimately, a court's role as a gatekeeper does not replace the adversary system.11 “Vigorous cross-examination, presentation of contrary evidence, and careful instruction on the burden of proof are the traditional and appropriate means of attacking shaky but admissible evidence.”12 “As a general rule, questions relating to the bases and sources of an expert's opinion affect the weight to be assigned that

opinion rather than its admissibility and should be left for the [trier of fact’s] consideration.”13 Notably, “rejection of expert testimony is the exception rather than the rule.”14 “Most of the safeguards provided for in Daubert are not as essential in a case … where a district judge sits as the trier of fact in place of a jury.”15 In a bench trial, the judge has “discretion to admit questionable technical evidence, although of course he must not give it more weight than it deserves.”16

9 Tidwell v. ABC Ins. Co., No. 3:19-CV-01242, 2023 WL 2497866 at *2 (W.D. La. Jan. 23, 2023) (citing Untied States v. Jones, 107 F.3d 1147 (6th Cir. 1997). 10 Cedar Lodge Plantation, L.L.C. v. CSHV Fairway View I, L.L.C., 753 F. App'x 191, 195 (5th Cir. 2018). 11 Daubert, 509 U.S. at 596, 113 S.Ct. 2786. 12 Daubert, 509 U.S. at 596, 113 S.Ct. 2786. 13 Primrose Operation Co. V. Nat'l Am. Ins. Co., 382 F.3d 546, 562 (5th Cir.2004) (citation omitted). 14 Eagle Oil & Gas Co., v. Travelers Prop. Cas. Co. of Am., No. 7:12-cv-00133-O, 2014 U.S. Dist. LEXIS 103537 at *10, 2014 WL 3744976, at *3 (N.D. Tex. July 30, 2014) (citation omitted). 15 Gibbs v. Gibbs, 210 F.3d 491, 500 (5th Cir. 2000). 16 Weinhoffer as Trustee of Offshore Specialty Fabricators LLC v. Davie Shoring, Inc., 479 F. Supp. 3d 330, 334 (E.D. La. 2020) (citation omitted). ANALYSIS The Hodges et al Motion, filed by LML, moves the Court to exclude or, alternatively, limit the testimony of four defense expert witnesses: Richard “Rick” Hodges (“Mr. Hodges”), Sam Crawford (“Mr. Crawford”), John Fenstermaker (“Mr.

Fenstermaker”), and Randall Rodrigue (“Mr. Rodrigue”).17 Weyerhaeuser opposes the motion.18 LML replied to Weyerhaeuser’s opposition.19 LML does not challenge the qualifications of these experts, but instead challenges their testimony on grounds of inadmissibility and irrelevance. A. Hodges Mr. Hodges is a landman with more than forty (40) years of experience in the oil and gas industry.20 His experience includes “general land and leasing activities to

facilitate oil and gas projects” and “negotiating oil and gas leases and other surface use agreements.”21 He was retained by Weyerhaeuser to give his expert opinion on industry custom and practices.22 Mr. Hodges rendered his expert report on January 30, 2024.23 First, the Court has determined that the Timber Lease is ambiguous because its terms are susceptible to either parties’ interpretation as to the relationship

between Weyerhaeuser’s surface rights and LML’s mineral rights with respect to the

17 R. Doc. 105. 18 R. Doc. 133. 19 R. Doc. 136. 20 R. Doc. 105-3 at 2. 21 R. Doc. 105-3 at 2. 22 R. Doc. 105-3 at 2. 23 R. Doc. 105-3 at 2. disputed third-party agreements.24 Accordingly, LML’s argument that Mr. Hodges’ testimony should be excluded because the Timber Lease is unambiguous is moot.25 LML also asserts that Mr. Hodges’ opinions are inadmissible legal conclusions

— for instance, interpreting provisions in Paragraphs 6 and 7 of the Timber Lease.26 Weyerhaeuser maintains that Mr.

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Related

Moore v. Ashland Chemical Inc.
151 F.3d 269 (Fifth Circuit, 1998)
Daubert v. Merrell Dow Pharmaceuticals, Inc.
509 U.S. 579 (Supreme Court, 1993)
United States v. Kathleen Kremser Jones
107 F.3d 1147 (Sixth Circuit, 1997)
United States v. Richard Hicks
389 F.3d 514 (Fifth Circuit, 2004)
Wagoner v. Exxon Mobil Corp.
813 F. Supp. 2d 771 (E.D. Louisiana, 2011)

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