Michael Reese Davis and St. Paul PFU, LLC, a Louisiana LLC v. George Stephen Guido, KFG Petroleum Corporation, a Mississippi Corporation and Mississippi State Oil and Gas Board

CourtCourt of Appeals of Mississippi
DecidedNovember 24, 2020
DocketNO. 2019-CC-00690-COA
StatusPublished

This text of Michael Reese Davis and St. Paul PFU, LLC, a Louisiana LLC v. George Stephen Guido, KFG Petroleum Corporation, a Mississippi Corporation and Mississippi State Oil and Gas Board (Michael Reese Davis and St. Paul PFU, LLC, a Louisiana LLC v. George Stephen Guido, KFG Petroleum Corporation, a Mississippi Corporation and Mississippi State Oil and Gas Board) is published on Counsel Stack Legal Research, covering Court of Appeals of Mississippi primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Michael Reese Davis and St. Paul PFU, LLC, a Louisiana LLC v. George Stephen Guido, KFG Petroleum Corporation, a Mississippi Corporation and Mississippi State Oil and Gas Board, (Mich. Ct. App. 2020).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI

NO. 2019-CC-00690-COA

MICHAEL REESE DAVIS AND ST. PAUL PFU, APPELLANTS/ LLC, A LOUISIANA LLC CROSS-APPELLEES

v.

GEORGE STEPHEN GUIDO, KFG APPELLEES/ PETROLEUM CORPORATION, A MISSISSIPPI CROSS-APPELLANTS CORPORATION AND MISSISSIPPI STATE OIL AND GAS BOARD

DATE OF JUDGMENT: 03/15/2019 TRIAL JUDGE: HON. GEORGE WARD COURT FROM WHICH APPEALED: ADAMS COUNTY CHANCERY COURT ATTORNEY FOR APPELLANTS: EDWARD GIBSON ATTORNEYS FOR APPELLEES: WILLIAM F. BLAIR ROBERT F. (FRANK) SPENCER ERIC LEE PATTERSON NATURE OF THE CASE: CIVIL - STATE BOARDS AND AGENCIES DISPOSITION: AFFIRMED - 11/24/2020 MOTION FOR REHEARING FILED: MANDATE ISSUED:

BEFORE CARLTON, P.J., GREENLEE AND LAWRENCE, JJ.

GREENLEE, J., FOR THE COURT:

¶1. This is an appeal by Michael Reese Davis and St. Paul PFU, LLC from a judgment

of the Chancery Court of Adams County amending and affirming an order of the State Oil

and Gas Board granting a permit to drill a well in the Mantua Field located in Adams County

to KFG Petroleum Corporation and its director and president, George Stephen Guido. We

affirm.

FACTS AND PROCEDURAL HISTORY ¶2. On July 2, 2018, Guido on behalf of KFG filed an application for a permit to drill the

Annie G. Barnum No. 5 well in the Mantua Field located in Adams County. The application

Guido submitted contained two errors, which were noted by one of the Oil and Gas Board’s

(“the Board”) supervisors, David Snodgrass. Guido had incorrectly identified the field as

“Wildcat” instead of Mantua. He also did not list the distance from the proposed well to the

nearest producing well. Upon finding the areas uncompleted, Snodgrass contacted Guido,

notifying him of the issues with the application. Guido promptly provided Snodgrass with

the correct information and consented to the Board’s staff making the needed informational

changes. Once the corrections were made, the Board issued a permit administratively on July

5, 2018.

¶3. On August 21, 2018, Michael Reese Davis filed an emergency petition requesting that

KFG’s drilling permit be revoked because Guido did not complete the application, and

Snodgrass had no legal authority to make the changes to the drilling application. Davis also

alleged that KFG’s clearing of timber and leveling of property constituted “waste.” Eight

days later, on August 29, 2018, the Board set the petition for a hearing. Before the hearing,

the Board’s chairman expressly limited the hearing to the permit’s validity. The chairman

stated that the Board had checked the property for waste and deemed it in compliance. Since

the property complied with the Board’s rules and regulations, the Board would not address

the waste allegation.

¶4. Therefore, before the Board, the only factual question was whether or not the permit

issued to Guido and KFG was valid. Davis argued that the application was an affidavit, and

2 Snodgrass lacked legal authority to make changes after submission since there was no written

rule or regulation. Snodgrass, an underground injection-control coordinator and supervisor

with the Board, testified that during the ten years he had been employed with the Board, it

had been the Board’s policy to assist with permit applications.

¶5. On September 12, 2018, the Board entered a final order finding that the Board’s

unwritten policy allowed informational changes after the submission of forms, and therefore

the permit was properly issued. Although the hearing had been limited to the permit’s

validity, the Board further held that KFG’s cutting of trees and leveling of the property were

normal actions used to prepare the oilfield, and thus Davis’s waste allegations were without

merit.

¶6. Davis appealed to the Chancery Court of Adams County. After reviewing the record

and the applicable law, the chancellor amended and affirmed the Board’s order. The

chancellor found that the drilling permit was valid but that the Board had gone beyond the

purpose of the hearing by addressing the waste claims in the final order.

¶7. Aggrieved by the chancery court’s judgment, Davis appeals. Davis claims on appeal

that the permit did not comply with the Board’s rules and regulations or statutory law. He

also claims that the Board’s unwritten policy allowing informational changes contradicts the

Board’s written rules and Mississippi statutes.

¶8. Aggrieved by the chancellor’s ruling regarding the Board’s ruling on Davis’s waste

allegations in its final order, Guido and KFG filed a cross-appeal. They claim that the Board

had jurisdiction to rule on the waste claims since Davis invoked the Board’s jurisdiction by

3 filing a petition alleging waste. Furthermore, they argue that the permit issue is moot.

STANDARD OF REVIEW

¶9. An appellate court reviews a chancery court’s decision regarding an agency’s action

under the same standard of review that the chancery court was bound to follow. Giles v.

Shaw Sch. Dist., 203 So. 3d 1165, 1169 (¶12) (Miss. Ct. App. 2016) (citing Miss. Sierra Club

Inc. v. Miss. Dep’t of Envtl. Quality, 819 So. 2d 515, 519 (¶15) (Miss. 2002)). In its review

of an administrative agency, the chancery court is limited to the record and the agency’s

findings. Bd. of Law Enf’t Officers Standards & Training v. Butler, 672 So. 2d 1196, 1199

(Miss. 1996) (citing Miss. Comm’n on Envtl. Quality v. Chickasaw Cnty. Bd. of Supervisors,

621 So. 2d 1211, 1215 (Miss. 1993)). The only grounds to overturn an administrative

agency’s decision is if an appellate court finds the agency’s ruling is “(1) unsupported by

substantial evidence, (2) arbitrary or capricious, (3) beyond the power of the administrative

agency to make, or (4) violated some statutory or constitutional right of the complaining

party.” Boyles v. Miss. State Oil & Gas Bd., 794 So. 2d 149, 152 (¶6) (Miss. 2001). If an

agency’s actions fail to meet one of those four conditions, an agency’s decision will remain

undisturbed. Id. “A rebuttable presumption in favor of the agency’s decision exists.” Id.

Therefore, the burden to prove that the court should overturn the agency’s decision based on

one of the above conditions is placed on the party challenging the decision. Ray v. Miss.

Dep’t of Pub. Safety, 172 So. 3d 182, 187 (¶16) (Miss. 2015).

¶10. Great deference is given to an administrative agency’s interpretation of its rule and

regulations, and a reviewing court may not substitute its judgment for that of the agency

4 where substantial evidence exists. Cent. Miss. Med. Ctr. v. Miss. Div. of Medicaid, 294 So.

3d 1121, 1125 (¶10) (Miss. 2020); see also Crossgates River Oaks Hosp. v. Miss. Div. of

Medicaid, 240 So. 3d 385, 387-88 (¶7) (Miss.

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Michael Reese Davis and St. Paul PFU, LLC, a Louisiana LLC v. George Stephen Guido, KFG Petroleum Corporation, a Mississippi Corporation and Mississippi State Oil and Gas Board, Counsel Stack Legal Research, https://law.counselstack.com/opinion/michael-reese-davis-and-st-paul-pfu-llc-a-louisiana-llc-v-george-missctapp-2020.