Louisiana Wetlands, LLC and New 90, LLC v. Energen Resources Corporation, Chevron USA, Inc., Southern Natural Gas Company, LLC, EP Energy E&P Company, LP, and Brammer Engineering, Inc.

CourtLouisiana Court of Appeal
DecidedNovember 30, 2023
Docket2022CA1169
StatusUnknown

This text of Louisiana Wetlands, LLC and New 90, LLC v. Energen Resources Corporation, Chevron USA, Inc., Southern Natural Gas Company, LLC, EP Energy E&P Company, LP, and Brammer Engineering, Inc. (Louisiana Wetlands, LLC and New 90, LLC v. Energen Resources Corporation, Chevron USA, Inc., Southern Natural Gas Company, LLC, EP Energy E&P Company, LP, and Brammer Engineering, Inc.) 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.

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Louisiana Wetlands, LLC and New 90, LLC v. Energen Resources Corporation, Chevron USA, Inc., Southern Natural Gas Company, LLC, EP Energy E&P Company, LP, and Brammer Engineering, Inc., (La. Ct. App. 2023).

Opinion

STATE OF LOUISIANA

COURT OF APPEAL

FIRST CIRCUIT

NO. 2022 CA 1169

LOUISIANA WETLANDS, LLC AND NEW 90, LLC

VERSUS

ENERGEN RESOURCES CORPORATION, CHEVRON USA, INC., SOUTHERN NATURAL GAS COMPANY, LLC, EP ENERGY E& P COMPANY, LP, AND BRAMMER ENGINEERING, INC.

Judgment Rendered: NOV 3 0 2023

On Appeal from the 16th Judicial District Court

In and for the Parish of St. Mary State of Louisiana District Court No. 130527

Honorable Suzanne deMahy, Judge Presiding

Bernard E. Boudreaux, Jr. Attorneys for PlaintiffAppellant, John T. Arnold James J. Bailey, 111, individually and Baton Rouge, LA as representative of the Successions of Willie Palfrey Foster and Fairfax Foster Bailey

Christopher W. Swanson Danielle C. Teutonico E. Blair Schilling Emma E. Daschbach Gladstone N. Jones, III James R. Swanson Kevin E. Huddell Lance C. McCardle Lindsay E. Reeves Michael P. Arata Rosa E. Acheson New Orleans, LA

Robert P. Fuhrer

Morgan City, LA ck' Z . C0AC,%.rS re Son S C 414 Bradley J. Schlotterer Attorneys for Plaintiff A - ppellant, Daniel B. Stanton Brammer Engineering, Inc. New Orleans, LA

Claire E. Juneau Attorneys for Defendant -Appellee, Edward H. Warner Chevron U.S. A., Inc. John C. Funderbunk Louis V. Gregoire, Jr. Baton Rouge, LA

Claudia Carrizales Louis M. Grossman Michael R. Phillips New Orleans, LA

Brian D. Melton David M. Peterson Elizabeth R. Taber Laranda M. Walker Houston, TX

Alan J. Berteau Attorneys for Defendant -Appellee, Richard D. McConnell, Jr. Southern Natural Gas Company, LLC Tyler M. Kostal Baton Rouge, LA

Chynna M. Anderson Rachel M. Scarafia New Orleans, LA

Andrew J. Brien Attorneys for Defendant -Appellee, David S. Landry Energen Resources Corporation Russell L. Foster New Orleans, LA

Esteban Herrera, Jr. Attorneys for Defendant -Appellee, Richard D. McConnell, Jr. EP Energy E& P Company, LP Samuel O. Lumpkin Baton Rouge, LA

Brittan J. Bush Attorneys for Defendant -Appellee, Court C. VanTassell BP America Production Company Emily C. Borgen George Arceneaux, III John S. Troutman Penny L. Malbrew Lafayette, LA

Kelly B. Becker New Orleans, LA

BEFORE: THERIOT, CHUTZ, AND HESTER, JJ.

2 HESTER, J.

In this legacy litigation,' James J. Bailey, III, individually and as the

representative of the Successions of Willie Palfrey Foster and Fairfax Foster Bailey

plaintiff'), appeals a judgment dated July 15, 2022, by which the district court

adopted the Louisiana Department of Natural Resources, Office of Conservation' s

LDNR"), Most Feasible Plan for Necessary Evaluation (" MFP") in accordance

with Louisiana Revised Statute 30: 29.' For the following reasons, we affirm the

district court' s judgment.

FACTS AND PROCEDURAL HISTORY

This case involves a 300 -acre tract of land located in St. Mary Parish, near the

Town of Franklin. It is undisputed that oil and gas exploration and production

activities were conducted on various areas of the property, beginning in 1948.

However, in December 2016, the original plaintiffs, Louisiana Wetlands, LLC and

New 90, LLC, 3 filed this lawsuit, alleging that soil and groundwater testing

conducted on the property revealed contamination and environmental damage

caused by these historical oil and gas operations. In the Petition for Damages,

As noted by the Louisiana Supreme Court, these types of actions are referred to as " legacy litigation" because they often arise from operations conducted many decades ago, leaving an unwanted " legacy" in the farm of actual or alleged contamination. See Marin v. Exxon Mobil Corporation, 2009- 2368, 2009- 2371 ( La. 10119110), 48 So. 3d 234, 238, n. 1,( citing Loulan Pitre, Jr., " Legacy Litigation" and Act 312 of 2006, 20 Tul. Envt. L.J. 347, 348 ( Summer 2007)).

z Louisiana Revised Statute 30: 29, sometimes referred to as " Act 312," has a stated legislative purpose of "ensur[ ing] that damage to the environment is remediated to a standard that protects the public interest. To this end, this Section provides the procedure for judicial resolution of claims for environmental damage to property arising from activities subject to the jurisdiction of the Department of Natural Resources, [ O] ffice of [C] onservation." La. R.S. 30: 29( A). Of note, the Commissioner for the Department of Natural Resources, Office of Conservation, has " jurisdiction and authority over all persons and property necessary to enforce effectively the provisions of this Chapter and all other laws relating to the conservation of oil or gas." La. R. S. 30: 4( A),

3 James J. Bailey, III, individually and as representative ofthe Successions of Willie Palfrey Foster and Fairfax Foster Bailey, is the sole remaining plaintiff in this suit. Through the second supplemental and amending petition, Louisiana Wetlands, LLC was removed as party plaintiff, and Mr. Bailey added as a new party plaintiff. All claims of New 90, LLC were later dismissed through summary judgment. Louisiana Wetlands, LLC v. Energen Resources Corporation, 2021- 0290 (La. App. 1st Cir. 10/ 4/ 21), 330 So. 3d 674, 680, writ denied, 2021- 01610 (La. 1/ 12122), 330 So. 3d 614.

3 numerous defendants were named, including appellees, Chevron U.S. A. Inc.

Chevron") and Southern Natural Gas Company, L.L.C. (" SNG"), who were

alleged to have " conducted, directed and participated in various oil and gas

exploration and production activities and/or working interest owners and/ or joint

venturers in the Franklin Field and on [ the] property," which activities included " the

operation or construction of various oil and gas facilities, including but not limited

to pits, sumps, pipelines, flowlines, tank batteries, wellheads, and measuring

facilities." The Petition also claimed that "[ d] efendants knew or should have known

that their day to day operations [... ] would cause the soil, surface waters and

groundwater of Plaintiffs' property to be contaminated[.] Defendants' failure to

timely remove or remediate this toxic pollution in the soils and groundwater of

Plaintiffs' property has allowed the pollution to migrate and spread, thereby causing

damages, including but not limited to, contained soil and groundwater, land loss, and

loss of timber[,]" and that "[ a] t no time did [ d] efendants issue any warning to

Plaintiffs that their disposal and discharge activities were hazardous to [ the]

property[.]"

In August and September of 2020, and in accordance with La. Code Civ. P.

art. 1563( A)( 1) 4, SNG and Chevron, respectively, filed limited admissions with the

district court, each admitting to being a " responsible party" for the environmental

damage occurring on plaintiffs property. As a result, the district court referred the

4 Louisiana Code of Civil Procedure article 1563( A)( 1) provides, " lilf any party admits liability for environmental damage pursuant to R.S. 30: 29, that party may elect to limit this admission of liability for environmental damage to responsibility for implementing the most feasible plan to evaluate, and if necessary, remediate all or a portion of the contamination that is the subject of the litigation to applicable regulatory standards, hereinafter referred to as a ` limited admission.' A limited admission shall not be construed as an admission of liability for damages under R.S. 30: 29( H), nor shall a limited admission result in a waiver of any rights or defenses of the admitting Pty

4 matter to LDNR', ordering SNG and Chevron to submit plans for evaluation or

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Related

Marin v. Exxon Mobil Corp.
48 So. 3d 234 (Supreme Court of Louisiana, 2010)
Sweet Lake Land & Oil Co. v. Oleum Operating Co.
229 So. 3d 993 (Louisiana Court of Appeal, 2017)

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Louisiana Wetlands, LLC and New 90, LLC v. Energen Resources Corporation, Chevron USA, Inc., Southern Natural Gas Company, LLC, EP Energy E&P Company, LP, and Brammer Engineering, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/louisiana-wetlands-llc-and-new-90-llc-v-energen-resources-corporation-lactapp-2023.