Seneca Resources Corp. v. SUPERIOR DIVING CO.

410 F. Supp. 2d 501, 2006 U.S. Dist. LEXIS 2503, 2006 WL 172279
CourtDistrict Court, E.D. Louisiana
DecidedJanuary 24, 2006
DocketCIV.A.05-250
StatusPublished

This text of 410 F. Supp. 2d 501 (Seneca Resources Corp. v. SUPERIOR DIVING CO.) is published on Counsel Stack Legal Research, covering District Court, E.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Seneca Resources Corp. v. SUPERIOR DIVING CO., 410 F. Supp. 2d 501, 2006 U.S. Dist. LEXIS 2503, 2006 WL 172279 (E.D. La. 2006).

Opinion

ORDER & REASONS

FALLON, District Judge.

Pending before the Court is Defendants Superior Diving Company, Inc. and Osprey Underwriting Agency, Inc.’s Joint Motion for Partial Summary Judgment (Rec.Doc. 19). For the following reasons, the motion is GRANTED.

I. BACKGROUND

On May 10, 1999, Seneca Resources Corporation (“Seneca”) and Superior Diving Company, Inc. (“Superior”) executed a Master Service Agreement (“MSA”). As of December 1, 2000, Seneca was the owner of the working interest in the oil, natural gas, and other minerals situated in the High Island Area, Block A-345 (“H.I.A-345”). The MSA, which governs Seneca’s purchase of material and services from Superior, was drafted by Seneca. Furthermore, the MSA set forth the procedures through which Seneca could place Orders to Superior for materials and services. In addition, the MSA stipulated that Superior would provide certain warranties to Seneca guaranteeing that its materials and services were in compliance with the MSA.

On December 12, 2003, Seneca purchased a “smart buoy” from Superior. The “smart buoy” was utilized in connection with Seneca’s drilling operations. During January 2004, Superior was notified by a third-party that there was a problem with Seneca’s “smart buoy.” Accordingly, Superior contacted Seneca by telephone to discuss the “smart buoy.” In the course of this telephone conversation, Superior informed Seneca that it would send a vessel to inspect the buoy.

On January 29, 2004, Superior arrived in Seneca’s H.I. A-345 and performed work on Seneca’s “smart buoy.” During the course of Superior’s work, Seneca alleges that the anchor or anchor chain/wire of Superior’s Vessel, the MTV GULF DIVER III, came in contact with Seneca’s well head. It is further alleged that this contact caused a large amount of gas to be released at high pressures which damaged the connected piping spools between the pipeline and the wellhead and allowed seawater to enter the pipeline. In addition, the force of the gas allegedly knocked the guard-cover for the hydraulic control umbilical off the wellhead. Furthermore, a small amount of condensate was also re *503 leased. As a result of the contact, Seneca alleges that it suffered approximately $749,246.23 in damages for the repair and replacement of the wellhead and $2,300,000 for loss of production at the well.

On February 19, 2004, Superior generated Invoice No.1986-04. This invoice reflected that Seneca owed Superior $13,856.69 for the work performed on Seneca’s “smart buoy.”

On January 28, 2005, Seneca filed suit against Superior and USI Gulf Coast Inc. (“USI”), Superior’s producing agent for its insurance coverage, alleging that Superior and USI were liable to it for the damages it incurred as a result of Superior’s work on its “smart buoy.” On February 22, 2005, Seneca amended its complaint to add Osprey Underwriting Agency, Ltd. (“Osprey”), Superior’s insurer, as a defendant and to eliminate any reference to USI.

II. PRESENT MOTION

In their present motion, Superior and Osprey assert that the work performed by Superior on January 29th, was governed by the MSA. Specifically, Superior and Osprey contend that Superior’s work was governed by the warranty provisions of the MSA and/or constitutes an Order under the MSA. On the other hand, Seneca argues that the work was neither covered by the warranty provisions of the MSA nor an Order under the MSA.

The resolution of this issue is important because section 20(b) of the MSA precludes the recovery of consequential or indirect damages arising from the breach of any obligation under the MSA or any Order, regardless of the fault of any party. Accordingly, if the work is governed by the MSA, it is Superior and Osprey’s contention that Seneca’s $2,300,000 in loss production damages are unrecoverable under the MSA.

III. LAW AND ANALYSIS

Summary judgment is appropriate if the record, as a whole, shows that there is no genuine issue of material fact and that the movant is entitled to judgment as a matter of law. Fed.R.Civ.P. 56(c); Celotex Corp. v. Catrett, 477 U.S. 317, 322, 106 S.Ct. 2548, 91 L.Ed.2d 265 (1986). To overcome summary judgment, “the nonmoving party must come forward with specific facts showing that there is a genuine issue for trial.” Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574, 587, 106 S.Ct. 1348, 89 L.Ed.2d 538 (1986). The Court must view the evidence in the light most favorable to the nonmovant and draw all reasonable inferences in the nonmov-ant’s favor. King v. Chide, 974 F.2d 653, 656 (5th Cir.1992).

In the present case, all the parties agree that the MSA was in effect on January 29, 2004. The parties, however, disagree as to whether the work performed on January 29th is governed by the MSA. Specifically, the dispute is to whether the work is governed by the warranty and/or order provisions of the MSA.

A. Warranty Provisions

Section 6 of the MSA governs warranties, quality standards, and inspections. Section 6(a)(1) provides that Superi- or warrants “that all material and services shall be free from defects in design, workmanship, quality, and materials.” Section 6(c) provides: “If [Superior] is notified of any defects and fails to promptly cure such defects, Company shall have the right to cure or to have such defects cured at [Superior’s] cost and expenses, and [Superior] shall promptly reimburse [Seneca] for such costs and expenses.” These provisions stipulate that once Superior is notified, through any source, that its materials, such as a “smart buoy,” are defective, Superior must promptly cure the defects. *504 Only after Superior fails to promptly cure the defects does Seneca have the right to cure or to have such defects cured at Superior’s cost and expenses.

In the present case, Superior was notified of a defect in the “smart buoy” by a third party. This notice, by itself, was enough to trigger Superior’s duty under section 6(c) to promptly cure the defect. Superior, however, went further and called Seneca to confirm the existence and discuss the extent of a defect in the “smart buoy.” At this point, Superior was certainly aware of a defect in the “smart buoy.” As such, Superior had the option to promptly cure the defect or do nothing and eventually reimburse Seneca for its costs and expenses. Superior chose to promptly cure the defect itself. Accordingly, the work performed by Superior on January 29, 2004, was governed by the MSA.

Seneca argues that Superior’s conduct indicates that Superior did not believe the work performed on January 29th was governed by the MSA. First, Seneca points out that Superior generated an invoice for the work.

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

Related

Cite This Page — Counsel Stack

Bluebook (online)
410 F. Supp. 2d 501, 2006 U.S. Dist. LEXIS 2503, 2006 WL 172279, Counsel Stack Legal Research, https://law.counselstack.com/opinion/seneca-resources-corp-v-superior-diving-co-laed-2006.