Nellie Pierce v. Atlantic Richfield Company

CourtLouisiana Court of Appeal
DecidedMarch 19, 2014
DocketCA-0013-1103
StatusUnknown

This text of Nellie Pierce v. Atlantic Richfield Company (Nellie Pierce v. Atlantic Richfield Company) 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.

Bluebook
Nellie Pierce v. Atlantic Richfield Company, (La. Ct. App. 2014).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

CA 13-1103

NELLIE PIERCE, ET AL.

VERSUS

ATLANTIC RICHFIELD COMPANY, ET AL.

**********

APPEAL FROM THE FIFTEENTH JUDICIAL DISTRICT COURT PARISH OF VERMILION, NO. 88702 HONORABLE EDWARD D. RUBIN, DISTRICT JUDGE

JOHN E. CONERY JUDGE

Court composed of J. David Painter, Phyllis M. Keaty, and John E. Conery, Judges.

CHEVRON’S MOTION TO STRIKE GRANTED; PLAINTIFFS’ MOTION TO STRIKE RENDERED MOOT; PLAINTIFFS’ REQUEST TO SUPPLEMENT THE RECORD ON APPEAL DENIED; MAY 2, 2013 AND MAY 8, 2013 JUDGMENTS AFFIRMED. Warren A. Perrin Perrin, Landry, deLaunay, Dartez & Ouellet 251 La Rue France Lafayette, Louisiana 70508 (337) 237-8500 COUNSEL FOR PLAINTIFFS/APPELLANTS: Nellie Pierce Russie Tiller David Pierce Pierce Enterprises, Inc.

Stuart H. Smith Michael G. Stag Sean S. Cassidy John Leonard Fontenot, Jr. Smith Stag, LLC 365 Canal Street, Suite 2850 New Orleans, Louisiana 70130 (504) 593-9600 COUNSEL FOR PLAINTIFFS/APPELLANTS: Nellie Pierce Russie Tiller David Pierce Pierce Enterprises, Inc.

Ralph Shelton Hubbard, III Céleste D. Elliot Rachel A. Clark Anne E. Briard 601 Poydras Street, Suite 2775 New Orleans, Louisiana 70130 (504) 568-1990 COUNSEL FOR DEFENDANT/APPELLEE: United States Fidelity & Guaranty Company

Michael E. Parker Allen & Gooch Post Office Box 81129 Lafayette, Louisiana 70598-1129 (337) 291-1350 COUNSEL FOR DEFENDANT/APPELLEE: United States Fire Insuarance Company John K. Nieset James A. Holmes P. Ryan Plummer Christovich & Kearney, LLP 601 Poydras Street, Suite 2300 New Orleans, Louisiana 70130 (504) 561-5700 COUNSEL FOR DEFENDANT/APPELLEE: Hartford Accident & Indemnity Co.

George B. Hall, Jr. Katie W. Myers Phelps Dunbar LLP 365 Canal Street, Suite 2000 New Orleans, Louisiana 70130-6534 (504) 566-1311 COUNSEL FOR DEFENDANT/APPELLEE: Great American Insurance Company of New York

Paul J. Hebert William H. L. Kaufman Valerie V. Guidry Ottinger Hebert, LLC Post Office Drawer 52606 Lafayette, Louisiana 70505-2606 (337) 232-2606 COUNSEL FOR DEFENDANT/APPELLEE: Henry Production Co., Inc.

Michael R. Phillips Louis M. Grossman Brittany B. Salup Shannon A. Shelton Kean Miller LLP 909 Poydras Street, Suite 3600 New Orleans, Louisiana 70112 (504) 585-3050 COUNSEL FOR DEFENDANT/APPELLEE: Chevron U.S.A. Inc. Carl D. Rosenblum Alida C. Hainkel Lauren C. Mastio Jones Walker LLP 201 St. Charles Avenue, 49th Floor New Orleans, Louisiana 70170 (504) 582-8296 COUNSEL FOR DEFENDANT/AMICUS BRIEF IN SUPPORT OF TRIAL COURT’S RULING: McMoRan Exploration Company CONERY, Judge.

Nellie Marceaux Pierce (“Mrs. Pierce”), Russie Tiller Pierce and David

Pierce, collectively the “Pierce Children”, and Pierce Enterprises, Inc. (“Pierce

Enterprises”), collectively the “Pierce Plaintiffs,” appeal the trial court’s May 2,

2013 judgment granting United States Fidelity & Guaranty Company (“USF&G”),

Hartford Accident & Indemnity Company (“Hartford”), Great American Insurance

Company of New York, f/k/a American National Fire Insurance Company (“Great

American”), and United States Fire Insurance Company’s (“US Fire”), collectively

the “Insurer Defendants,” exceptions of no right of action dismissing the entirety of

the Pierce Plaintiffs’ case against the named defendants.

The Pierce Plaintiffs also appeal the trial court’s separate May 8, 2013

judgment which also granted, for the same reasons, the exception of no right of

action filed on behalf of Henry Production Company, Inc. (“Henry”), and adopted

by Chevron U.S.A., Inc. 1 (“Chevron”), and also dismissed the Pierce Plaintiffs’

claims against Henry and Chevron with prejudice. For the following reasons, we

affirm.

FACTS AND PROCEDURAL HISTORY

The Pierce Plaintiffs originally filed suit on May 29, 2009. The original

petition was followed by three supplemental and amending petitions, the last of

which was filed on January 27, 2012. The Pierce Plaintiffs claimed that their land

in Vermilion Parish was contaminated by a number of defendants in a variety of

ways, which were all related to actions or inactions connected to oil and gas 1 Chevron filed a number of exceptions which included the dilatory exceptions of improper cumulation, vagueness and ambiguity, as well as the peremptory exception of no cause of action for depositor/depositary liability, punitive damages, and fraud. Out of an abundance of caution, Chevron also adopted the exceptions filed by the other defendants which included the peremptory exception of no right of action that is the subject of this appeal. operations. The allegations in the Pierce Plaintiffs’ petitions involved three areas

of the property. To attempt to avoid confusion, the three areas of property are

referred to in the Pierce Plaintiffs’ “Second Supplemental and Restated Petition” as

“(1) the Larry Landry dump (“the waste dump site”); (2) the ARCO production

area; and (3) the Southland pipeyard.[2]”

The Pierce Plaintiffs specifically alleged that defendant, Home Industry

Disposal Company, Inc. (“HIDCO”), was responsible for damage to the Larry

Landry dump, hereinafter referred to as the waste dump site. In the mid-1970s,

HIDCO began operating on the waste dump site pursuant to a verbal agreement

with the longtime owner, Mr. Casey Pierce (“Mr. Pierce”). Mr. Pierce, ancestor in

title to the Pierce Children, acquired the property at issue through a credit deed in

1944. HIDCO began using the site for disposing of domestic waste, but ultimately

began to also dispose of waste related to oil and gas operations. It is undisputed

that HIDCO ceased operations at the waste dump site in 1979.

After Mr. Pierce passed away in 1998, a “Judgment of Possession” was

signed on August 19, 1998, giving ownership of the waste dump site to the Pierce

Children only.3 On February 24, 2011, the Pierce Children sold the waste dump

site to HIDCO via “Cash Sale.” Plaintiffs’ counsel maintained at oral argument

that the “Cash Sale” document reserved the Pierce Children’s claim for property

damage against potential insurers of HIDCO. However, no reservation of rights is

contained within the four corners of the February 24, 2011 “Cash Sale” document.

2 The Pierce Plaintiffs have settled their claims with Atlantic Richfield (“ARCO”), which is the defendant who allegedly contaminated the area designated as “the ARCO Production area.” ARCO has been dismissed from the lawsuit. 3 It is undisputed that neither Mrs. Nellie Marceaux Pierce nor Pierce Enterprises inherited or owned any of the property that is the subject of this lawsuit. The only plaintiffs who have an interest in the property are the Pierce Children, Russie Tiller Pierce, and David Pierce. The judgments in question and the appeal, however, were taken on behalf of all “Pierce Plaintiffs.”

2 HIDCO remains a defendant in the lawsuit despite what has been termed by

counsel for the Pierce Plaintiffs as a “Compromise Receipt and Release

Agreement” (“Agreement”) between the Pierce Plaintiffs and HIDCO. According

to counsel for the Pierce Plaintiffs, the terms of the Agreement purport to

specifically reserve the Pierce Plaintiffs’ rights against HIDCO and its insurers, in

this case the Insurer Defendants, “with respect to any and all insured actions and

inactions.”

The Pierce Plaintiffs, subsequent to oral argument before this court,

requested that the Agreement be submitted into the record on appeal. The Pierce

Plaintiffs admitted in their briefing in support of the request that the Agreement

was not admitted into evidence at the hearing before the trial court.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Holly & Smith v. St. Helena Cong. Facility
943 So. 2d 1037 (Supreme Court of Louisiana, 2006)
Hood v. Cotter
5 So. 3d 819 (Supreme Court of Louisiana, 2008)
Reese v. STATE DEPT. OF PUBLIC SAFETY
866 So. 2d 244 (Supreme Court of Louisiana, 2004)
Descant v. Adm'rs of Tulane Educ. Fund
639 So. 2d 246 (Supreme Court of Louisiana, 1994)
Marsh Engineering Inc. v. Parker
883 So. 2d 1119 (Louisiana Court of Appeal, 2004)
Turner v. Busby
883 So. 2d 412 (Supreme Court of Louisiana, 2004)
Badeaux v. Southwest Computer Bureau, Inc.
929 So. 2d 1211 (Supreme Court of Louisiana, 2006)
Denoux v. Vessel Management Services, Inc.
983 So. 2d 84 (Supreme Court of Louisiana, 2008)
J. L. Philips & Co. v. Barber
91 So. 293 (Supreme Court of Louisiana, 1922)

Cite This Page — Counsel Stack

Bluebook (online)
Nellie Pierce v. Atlantic Richfield Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/nellie-pierce-v-atlantic-richfield-company-lactapp-2014.