State of Louisiana and the Vermilion Parish School Board v. Louisiana Land & Exploration Company

CourtLouisiana Court of Appeal
DecidedMarch 5, 2025
DocketCW-0023-0550
StatusUnknown

This text of State of Louisiana and the Vermilion Parish School Board v. Louisiana Land & Exploration Company (State of Louisiana and the Vermilion Parish School Board v. Louisiana Land & Exploration 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
State of Louisiana and the Vermilion Parish School Board v. Louisiana Land & Exploration Company, (La. Ct. App. 2025).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

23-550 consolidated with 24-53

STATE OF LOUISIANA AND THE VERMILION PARISH SCHOOL BOARD

VERSUS

LOUISIANA LAND & EXPLORATION COMPANY, ET AL.

**********

APPEAL FROM THE FIFTEENTH JUDICIAL DISTRICT COURT PARISH OF VERMILION, NO. 82,162 HONORABLE ROYALE L COLBERT, JR., DISTRICT JUDGE

GARY J. ORTEGO JUDGE

Court composed of D. Kent Savoie* 1 , Gary J. Ortego, and Ledricka J. Thierry, Judges.

AFFIRMED.

Savoie, J- Concurs, with written reason.

1 *Honorable D. Kent Savoie participated in this decision by appointment of the Louisiana Supreme Court as Judge Ad Hoc. Jerold Edward Knoll The Knoll Law Firm P. O. Box 426 Marksville, LA 71351 (318) 253-6200 COUNSEL FOR PLAINTIFF/APPELLEE: The Vermilion Parish School Board

Donald T. Carmouche Victor L. Marcello Diane Adele Owen John Hogarth Carmouche William R. Coenen, III Brian T. Carmouche Christopher D. Martin Ross J. Donnes Todd J. Wimberley Caroline H. Martin Leah C. Poole Talbot, Carmouche & Marcello 17405 Perkins Road Baton Rouge, LA 70810 (225) 400-9991 COUNSEL FOR PLAINTIFF/APPLLEE: The Vermilion Parish School Board

Jeffrey J. Gelpi Michael R. Phillips Anne C. Lemelin Kean, Miller, LLP 909 Poydras St., #3600 New Orleans, LA 70112 (504) 585-3050 COUNSEL FOR DEFENDANT/APPELLANT: Union Oil Company of California

Louis Victor Gregoire, Jr. Kean, Miller, LLP 400 Convention Street, #700 Baton Rouge, LA 70802 (225) 387-0999 COUNSEL FOR DEFENDANT/APPELLANT: Union Oil Company of California Grady Joseph Abraham Attorney at Law 5040 Ambassador Caffery #200 Lafayette, LA 70508 (337) 234-4523 COUNSEL FOR PLAINTIFF/APPELLEE: The Vermilion Parish School Board

Andrew M. Stakelum King & Spalding 1100 Louisiana, Ste 4000 Houston, TX 77002 (713) 751-3200 COUNSEL FOR DEFENDANT/APPELLANT: Union Oil Company of California

Michael L. Heaton Talbot, Carmouche & Marcello 17405 Perkins Road Baton Rouge, LA 70810 (225) 400-9991 COUNSEL FOR PLAINTIFF/APPELLEE: The Vermilion Parish School Board

Dylan T. Scully Kean, Miller, LLP 400 Convention Str. Ste. 700 Baton Rouge, LA 70821 (225) 387-0999 COUNSEL FOR DEFENDANT/APPELLANT: Union Oil Company of California

Claire E. Juneau Robert E. Meadows King & Spalding, LLP 1100 Louisiana, Ste 4000 Houston, TX 77002-5213 (713) 751-3200 COUNSEL FOR DEFENDANT/APPELLANT: Union Oil Company of California ORTEGO, Judge. The Vermilion Parish School Board brought action to have oil company

deposit additional funds per a final Most Feasible Plan under Act 312 to remediate

oil-field waste and contamination on 1,200 acres of mostly submerged wetlands

owned by the state and managed by the school board. The trial court ordered the oil

company to deposit funds to, inter alia, remediate groundwater, reenter a certain

saltwater disposal well, and remediate soil. The oil company appeals. We affirm.

FACTS AND PROCEDURAL HISTORY

This case involves legacy litigation under Act 312 of 2006. In Marin v. Exxon

Mobil Corp., 09-2368, 09-2371, p. 1 (La. 10/19/10), 48 So.3d 234, 238, n.1, the

Louisiana Supreme Court explained:

“Legacy litigation” refers to hundreds of cases filed by landowners seeking damages from oil and gas exploration companies for alleged environmental damage in the wake of this Court’s decision in Corbello v. Iowa Production, 02-826 (La. 2/25/03), 850 So.2d 686. These types of actions are known as “legacy litigation” because they often arise from operations conducted many decades ago, leaving an unwanted “legacy” in the form of actual or alleged contamination. Loulan Pitre, Jr., “Legacy Litigation” and Act 312 of 2006, 20 Tul. Envt. L.J. 347, 34 (Summer 2007).

In 2004, the State of Louisiana and the Vermilion Parish School Board

(collectively “VPSB”) filed suit against Union Oil Company of California, Union

Exploration Partners (collectively, “Unocal”), Chevron U.S.A., Inc., Chevron

Midcontinent LP, and Carrollton Resources, LLC as Defendants. Pursuant to a 1935

mineral lease and a 1994 surface lease, Unocal conducted oil exploration and oilfield

production on the VPSB land for several decades.

Under the 2006 version of La.R.S. 30:29, often referred to as Act 312, VPSB

sought remediation of certain lands known as Section Sixteen lands, the sections

numbered 16 in each township of Louisiana set aside for the purpose of supporting

public schools. The legislature’s intent in passing Act 312 was to ensure that funds awarded for remediation of contaminated property would indeed be spent to

remediate the property and bring the land up to current environmental standards. See

La.R.S. 30:29(A), (G) (2006); See also, State v. La. Land and Expl. Co., 12-0884,

(La. 1/30/13), 110 So. 3d 1038.

During discovery, and pursuant to provision (C) of La.R.S. 30:29 (2006),

Unocal entered a limited admission pursuant to the La.Code of Civ.P. art. 1563,

wherein it admitted responsibility for environmental damage, as defined by Act 312.

This was ostensibly done for the sole purpose of ensuring that evaluation and

remediation of the property could begin efficiently and promptly after trial, once a

Most Feasible Plan (MFP) for doing so was proposed by each litigant and a public

hearing was held before the Louisiana Department of Natural Resources (“LDNR”),

who then submitted its recommendation regarding a MFP to the trial court. Unocal’s

admission was not an admission of any of VPSB’s private causes of action.

Trial was held in May of 2015. At the conclusion of the fourteen-day trial, the

jury returned a verdict finding Unocal had contaminated the land and awarding VPSB

$3,500,000.00 for remediation of the land in compliance with applicable state

standards and regulations pursuant to Act 312. Additionally, the jury awarded

$1,500,000.00 in damages for VPSB’s private strict liability action. The jury denied

all other VPSB causes of action. VPSB filed a motion for new trial, alleging that the

jury verdict was inconsistent because the jury awarded damages for remediation and

strict liability but awarded no damages for its contract actions. The trial court denied

the motion.

This court in State v. La. Land & Expl. Co., 17-830, p. 5 (La.App. 3 Cir.

3/14/18), 241 So.3d 1258, 1264, writ denied, 18-476 (La. 9/28/18), 252 So.3d 924,

noted the procedure following a trial as follows:

2 [A] defendant who has admittedly caused, or has been found to have caused, environmental damage to property must submit a plan for remediation of the damage to the LDNR. La.R.S. 30:29(C)(1). The plaintiff may also submit a plan for the LDNR’s consideration. La.R.S. 30:29(C)(1). The LDNR then conducts a public evidentiary hearing. La.R.S. 30:29(C)(2)(a).

After the hearing, the LDNR considers any plans properly submitted and ultimately issues its own plan, which may or may not approve and adopt all or part of either submitted plan. The LDNR plan must be the plan it finds to be the “most feasible plan” within the meaning of La.R.S. 30:29(C)(2)(a).

Prior to the above, the court stated the following:

Thereafter, the [LDNR] holds a public hearing on the submissions. La. R.S. 30:29(C)(2). Within a time set by the statute, the [LDNR] determines, based on evidence submitted, the most feasible plan to accomplish the evaluation/remediation of the environmental damage while protecting the health, safety and welfare of the public. Id.

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State of Louisiana and the Vermilion Parish School Board v. Louisiana Land & Exploration Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-louisiana-and-the-vermilion-parish-school-board-v-louisiana-land-lactapp-2025.