Ralph Rather and Enexco, Inc. v. AAA Well Service, LLC

CourtCourt of Appeals of Texas
DecidedJune 29, 2018
Docket05-17-00262-CV
StatusPublished

This text of Ralph Rather and Enexco, Inc. v. AAA Well Service, LLC (Ralph Rather and Enexco, Inc. v. AAA Well Service, LLC) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ralph Rather and Enexco, Inc. v. AAA Well Service, LLC, (Tex. Ct. App. 2018).

Opinion

Affirmed and Opinion Filed June 29, 2018

S In The Court of Appeals Fifth District of Texas at Dallas No. 05-17-00262-CV

RALPH RATHER AND ENEXCO, INC., Appellants V. AAA WELL SERVICE, LLC, Appellee

On Appeal from the 192nd Judicial District Court Dallas County, Texas Trial Court Cause No. DC-15-02337

MEMORANDUM OPINION Before Chief Justice Wright, Justice Bridges, and Justice Evans Opinion by Justice Bridges Ralph Rather and Enexco, Inc. appeal the trial court’s judgment, following a jury trial,

awarding AAA Well Service, LLC $34,464.64 on its breach of contract claim against Enexco and

its piercing the corporate veil/alter ego claim against Rather individually. In four issues, Rather

and Enexco argue the evidence is legally and factually insufficient to show they committed “actual

fraud” and that “they did it primarily for Rather’s direct personal benefit.” We affirm the trial

court’s judgment.

Rather is the president and fifty percent owner of Enexco, an oil and gas operating company

that previously operated wells in various parts of Texas. By the time of trial, Enexco had “pretty

much shut down.” Rather was also president and fifty percent owner of N&R Resources, Inc., a

company that maintained working interests in a number of wells operated by other companies, including some wells operated by Enexco. AAA provides workover rigs to already-drilled oil and

gas wells and repairs the wells.

In 2010, N&R obtained 100% of the working interest on a lease in Hardeman County,

Texas. N&R assigned seventy-five percent of the working interest to other non-operating working

interest owners and retained twenty-five percent. N&R hired Enexco to operate the “Fowler Well”

on the lease because N&R was not licensed to operate wells in Texas, but Enexco was a licensed

operator. Enexco received overhead costs for serving as operator and assuming monetary risks

associated with the well. Overhead costs included “taking care of all the accounting functions, all

the regulatory functions” and “an overhead amount on a monthly basis after production was

established.” Rather testified that, because he was president and fifty-percent owner of both N&R

and Enexco, it was to his benefit to hire an operator at the cheapest price possible. With respect

to the Fowler Well, Enexco agreed to operate the well for only its overhead costs with no additional

profit.

Rather testified that Enexco hired him individually to serve as a consultant in connection

with the Fowler Well. AAA’s counsel asked if Rather was paid $68,000 as a consultant on the

Fowler Well. Rather denied being paid $68,000 and said he was paid “I think $3500.” AAA’s

counsel showed Rather an October 11, 2013 settlement statement from Enexco used to show

working interest owners the amounts they owed for their proportionate shares of ownership in the

well. The statement showed a payment to Rather of $3000, which Rather did not deny receiving.

However, Rather denied receiving payments of $27,601.35 and $20,115.61 that were listed on the

statement. Rather testified he was not aware there were other settlement statements showing

amounts charged by Enexco for Rather’s invoices.

In December 2013, Rather contacted AAA, and Enexco thereafter contracted with AAA to

provide a rig and crew to work the Fowler Well. Although AAA performed the work, Rather and

–2– Enexco never paid. In February 2015, AAA sued Enexco and Rather asserting, among other

things, a breach of contract claim against Enexco and a piercing the corporate veil/alter ego claim

against Rather individually. In November 2016, the case was tried before a jury. AAA’s

operations manager, Deecye Bedell, testified AAA performed work on the Fowler Well in August

and September 2013. Bedell had “a lot of discussions” with Rather about paying AAA before

contracting with Enexco in December 2013, and Rather stated he “could and would pay AAA for

its services.” Bedell relied on Rather’s statement in deciding to send a rig and crew to perform the

services on the Fowler Well in December 2013, and AAA performed the work. Jin Chua, manager

of AAA’s accounting, testified an invoice for $34,464.64 was mailed to Enexco on January 22,

2014, but the invoice was never paid.

Rather testified that, “shortly before” AAA worked on the Fowler Well, Rather personally

guaranteed payment to AAA by another company for which Enexco was doing a contract operating

job. Rather testified he first received AAA’s invoice in this case when he was served with AAA’s

lawsuit in February 2015. Rather testified that, in 2010, Enexco had “a well that had a significant

cost overrun,” and a number of investors left Rather “holding the bag.” In 2011 and 2012, Enexco

“had some outstanding debts and liabilities.” As of November 2013, Rather testified “we had

some problems because of the cost overrun and I was trying to remedy that by paying – I paid a

lot of it out of my pocket.” Rather testified he and his father “levered some of our assets with

Enexco to pay the bills.” Rather confirmed that Platinum Pipe Rentals made a claim for an unpaid

amount of $21,535.59 as of October 15, 2013 and ultimately obtained a default judgment in that

amount for work performed on the Fowler Well. Rather testified another vendor, Weatherford,

had a balance due for work performed in August 2013. On April 28, 2014, Weatherford notified

Rather that his account with Weatherford was closed because of a total past due balance of

$11,366.31.

–3– Rather testified that his brother Michael was not an employee of Enexco, but “on occasion

he would be an independent contractor.” Rather testified Michael charged $3065.27 to Enexco in

connection with the Fowler Well. AAA’s counsel referred Rather to a file he and Enexco produced

showing invoices and receipts for charges billed to Enexco by Michael. The invoices showed

Michael charged for, among other things, hotels, mileage on his personal vehicle, gasoline for his

personal vehicle, $577.36 for tires for his personal vehicle, $207.99 for a tuneup of his personal

vehicle, cigarettes, $219.73 for work boots, and a “double hot caramel sundae” from Braum’s.

Rather testified Enexco kept the invoices in Michael’s “file of reimbursements,” but Rather had

“no idea” whether the invoices were actually paid to Michael. Rather testified that his son and

Michael’s son also worked on the Fowler Well, and they worked together on the same day to paint

a “tank battery” and both charged for “those same services.” AAA’s counsel asked whether, if

Enexco had “not been paying tens of thousands of dollars to [Rather], Michael Rather your brother,

your nephew and your son,” Enexco would have had enough money to pay AAA. Rather replied

that “there was money there to pay AAA,” but he “never received an invoice until two years later.”

Rather denied that Enexco knew by December 2013 “that its financial difficulties had put them in

a position it was going to be winding down,” and “rather than give up what assets it had to pay

third-party creditors,” Enexco “funneled that money out” to Rather, his brother, his nephew, and

his son.

The jury found that AAA and Enexco agreed that AAA would perform work at the Fowler

Well in exchange for payment, Enexco failed to comply with the agreement, $34,464.64 would

fairly compensate AAA for its damages, and Rather was responsible for the conduct of Enexco.

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