Murphy Oil USA Inc v. Loves Travel Stops & Country Stores Inc

CourtDistrict Court, N.D. Texas
DecidedMarch 3, 2021
Docket3:18-cv-01345
StatusUnknown

This text of Murphy Oil USA Inc v. Loves Travel Stops & Country Stores Inc (Murphy Oil USA Inc v. Loves Travel Stops & Country Stores Inc) is published on Counsel Stack Legal Research, covering District Court, N.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Murphy Oil USA Inc v. Loves Travel Stops & Country Stores Inc, (N.D. Tex. 2021).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS DALLAS DIVISION

MURPHY OIL USA, INC., § § Plaintiff, § § v. § §

LOVE’S TRAVEL STOPS & § COUNTRY STORES, INC; GEMINI § Civil Action No. 3:18-CV-01345-X MOTOR TRANSPORT; MUSKET § CORPORATION; STANLEY § BOWERS; SCOTT DODD; LARRY § JONES; MICHAEL WOOD; ROY § TAYLOR; MATT TUGMAN; § EDWARD WASHINGTON; and § ALAN SVAJDA, §

§ Defendants.

MEMORANDUM OPINION AND ORDER

The Court’s memorandum opinion and order dated December 10, 2020 [Doc. 96] and final judgment [Doc. 95] are hereby WITHDRAWN and the Courts enters the following order. Murphy Oil USA, Inc. (Murphy) sued Love’s Travel Stops & Country Stores, Inc. (Love’s), Gemini Motor Transport (Gemini), Musket Corporation, and eight individual fuel-carrier drivers for civil theft, conversion, and unjust enrichment stemming from an alleged conspiracy to steal diesel fuel during Hurricane Harvey. The defendants collectively filed a Motion for Summary Judgment [Doc. No. 34]. In the now-withdrawn opinion, the Court held that Murphy waived its claims when it charged, and Love’s paid, a “special” or high price for the fuel. That opinion also contained unnecessary analysis from Murphy’s own records demonstrating the high nature of that special price, which was the basis for Murphy’s motion for reconsideration. Because that analysis was unnecessary, and apparently greatly vexed Murphy, the Court has revised its opinion to stand on the key facts that

Murphy ended this dispute under the doctrine of waiver when it charged and Love’s paid the special price. Accordingly, the Court GRANTS the motion for summary judgment [Doc. 34] and DENIES Murphy’s motion to alter or amend the judgment [Doc. 100]. I. Factual Background Murphy sells fuel both at retail and as a wholesaler. Murphy utilizes third-

party terminals to store fuel in support of both business lines. Fuel held at these terminals is designated either available for wholesale or “branded,” meaning only available for use at Murphy retail locations. Fuel carriers use “loading codes” to retrieve fuel at the terminal and coordinate billing. Branded fuel is retrieved only by using a special loading code that Murphy provides exclusively to carriers designated for hauling its fuel. Hurricane Harvey brought with it an abundance of water and a shortage of

fuel. To ensure its retail locations would have an adequate supply, Murphy directed the Frost Terminal to designate all Murphy diesel fuel stored there as branded fuel. Gemini is a fuel carrier who is designated to carry fuel to Murphy stores, and Love’s is another retail fuel business that sometimes buys wholesale fuel from Murphy. During the hurricane, Gemini used the special Murphy loading code to load 27 trucks with 220,000 gallons of branded Murphy diesel fuel. Rather than carry the fuel to Murphy locations, however, Gemini delivered the fuel to Love’s stores around Texas. This caused Murphy to have an insufficient diesel supply to support its own stores. After discovering Gemini carried the branded fuel to non-Murphy stores,

Murphy billed Love’s for the branded diesel fuel at a “special” rate $0.29 per gallon higher than its posted wholesale prices on those days. Love’s promptly paid the invoice in full. Two weeks later, Murphy demanded the defendants also pay for lost opportunities, profits, and damage to its reputation. Murphy then filed this lawsuit to recover lost profits from sales of the fuel and related merchandise. Murphy alleges that the defendants conspired to commit civil theft under the Texas Theft Liability

Act, common law conversion, and were unjustly enriched by their conduct. The defendants maintain that Murphy waived any and all claims related to the fuel when it instead chose to bill the defendants at an increased rate and they paid. II. Legal Standards A. Summary Judgment Summary judgment is appropriate only if, viewing the evidence in the light most favorable to the non-moving party, “the movant shows that there is no genuine

dispute as to any material fact and the movant is entitled to judgment as a matter of law.”1 “A fact is material if it ‘might affect the outcome of the suit’” and a “factual dispute is genuine ‘if the evidence is such that a reasonable jury could return a verdict for the nonmoving party.’”2

1 FED. R. CIV. P. 56(a). 2 Thomas v. Tregre, 913 F.3d 458, 462 (5th Cir. 2019) (citing Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986)). B. Waiver of Claims Under Texas law, waiver is defined as “an intentional relinquishment of a known right or intentional conduct inconsistent with claiming that right.”3 “Waiver

is largely a matter of intent, and for implied waiver to be found through a party’s actions, intent must be clearly demonstrated by the surrounding facts and circumstances.”4 Although waiver is a question of intent, it need not be express.5 Conduct sufficiently demonstrates intent to waive a right if “in light of the surrounding facts and circumstances, it is unequivocally inconsistent with claiming that right.”6 Waiver is a question of law when the surrounding facts and

circumstances are undisputed.7 III. Analysis The defendants argue that Murphy waived all claims related to the branded fuel when it invoiced the defendants, and accepted payment, for the fuel at a special price. Murphy dismisses this transaction as merely an attempt “recoup its losses as quickly as possible.”8 The Court will evaluate waiver with respect to each cause of action.

A. Texas Theft Liability Act

3 Jernigan v. Langley, 111 S.W.3d 153, 156 (Tex. 2003). 4 Id. 5 LaLonde v. Gosnell, 593 S.W.3d 212, 219 (Tex. 2019). 6 Id. 7 Jernigan, 111 S.W.3d at 156–57. 8 Doc. No. 59 at 8. The Texas Theft Liability Act provides a cause of action for victims of theft to recover any resulting damages.9 Under the Act, “a person who has sustained damages resulting from theft may recover . . . the amount of actual damages found

by the trier of fact and, in addition to actual damages, damages awarded by the trier of fact in a sum not to exceed $1,000.”10 To recover, “a plaintiff must demonstrate damages resulting from a theft.”11 The undisputed facts and circumstances of this case demonstrate Murphy’s intent to waive any Texas Theft Liability claims against the defendants. Choosing to forgo litigation in favor of billing the defendants for the fuel at a “special” rate that

Murphy calculated by hand is unequivocally inconsistent with intent to later assert a Texas Theft Liability Act claim to recover those same damages. Murphy even admits that it issued the invoices for the express purpose of “recoup[ing] its losses as quickly as possible.”12 And recouping losses is exactly the goal of lawsuits to recover damages. If Murphy incorrectly calculated by hand its special price it charged Love’s, then it should have either calculated that rate carefully or waited for the fullness of litigation to make that calculation.

Although only Love’s paid Murphy’s invoice, the implied waiver is effective for all the defendants. Joint and several liability rules allow a plaintiff to recover damages from multiple liable defendants under certain circumstances.13 However,

9 TEX. CIV. PRAC. & REM. CODE § 134.003(a). 10 Id. § 134.005(a)(1). 11 Duaz v. Valdez, 571 S.W.3d 795, 805 (Tex. App.—Houston [1st Dist.] 2018, no pet.). 12 Doc. No. 59 at 8. 13 See Bluestar Energy, Inc. v. Murphy,

Related

Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
BMG Direct Marketing, Inc. v. Peake
178 S.W.3d 763 (Texas Supreme Court, 2005)
Best Buy Co. v. Barrera
248 S.W.3d 160 (Texas Supreme Court, 2007)
R.M. Dudley Construction Co. v. Dawson
258 S.W.3d 694 (Court of Appeals of Texas, 2008)
Nelson v. Najm
127 S.W.3d 170 (Court of Appeals of Texas, 2003)
Jernigan v. Langley
111 S.W.3d 153 (Texas Supreme Court, 2003)
Tilton v. Marshall
925 S.W.2d 672 (Texas Supreme Court, 1996)
Bluestar Energy, Inc. v. Murphy
205 S.W.3d 96 (Court of Appeals of Texas, 2006)
Heldenfels Bros. v. City of Corpus Christi
832 S.W.2d 39 (Texas Supreme Court, 1992)
Berry v. Golden Light Coffee Company
327 S.W.2d 436 (Texas Supreme Court, 1959)
United Mobile Networks, L.P. v. Deaton
939 S.W.2d 146 (Texas Supreme Court, 1997)
Berry v. Lee
428 F. Supp. 2d 546 (N.D. Texas, 2006)
Travis Thomas v. Michael Tregre
913 F.3d 458 (Fifth Circuit, 2019)
Sky View at Las Palmas, LLC v. Mendez
555 S.W.3d 101 (Texas Supreme Court, 2018)
Baker v. Great Northern Energy, Inc.
64 F. Supp. 3d 965 (N.D. Texas, 2014)

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Murphy Oil USA Inc v. Loves Travel Stops & Country Stores Inc, Counsel Stack Legal Research, https://law.counselstack.com/opinion/murphy-oil-usa-inc-v-loves-travel-stops-country-stores-inc-txnd-2021.