Superior Energy Services, Inc. and SESI, LLC v. Sonic Petroleum Services, Ltd. and Lonnie's Well Service Co., General Partner

CourtCourt of Appeals of Texas
DecidedNovember 4, 2010
Docket11-10-00067-CV
StatusPublished

This text of Superior Energy Services, Inc. and SESI, LLC v. Sonic Petroleum Services, Ltd. and Lonnie's Well Service Co., General Partner (Superior Energy Services, Inc. and SESI, LLC v. Sonic Petroleum Services, Ltd. and Lonnie's Well Service Co., General Partner) 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
Superior Energy Services, Inc. and SESI, LLC v. Sonic Petroleum Services, Ltd. and Lonnie's Well Service Co., General Partner, (Tex. Ct. App. 2010).

Opinion

Opinion filed November 4, 2010

                                                           In The

  Eleventh Court of Appeals

                                                       __________

                                             No. 11-10-00067-CV

    SUPERIOR ENERGY SERVICES, INC. AND SESI, LLC, Appellants

                                                             V.

       SONIC PETROLEUM SERVICES, LTD. AND LONNIE’S WELL

                      SERVICE CO., GENERAL PARTNER, Appellees

                                   On Appeal from the 358th District Court

                                                             Ector County, Texas

                                                  Trial Court Cause No. D-125,961

                                                                  O P I N I O N

            In this interlocutory appeal, Superior Energy Services, Inc. (Superior) and SESI, LLC (SESI) appeal the trial court’s orders overruling their special appearance motions.  The record demonstrates that both companies have the requisite contacts with Texas and that jurisdiction over them in the underlying suit would not violate constitutional guarantees of substantive due process.  We affirm.

Background

Brian Shoemaker was a limited partner in and manager of Sonic Petroleum Services, Ltd., whose principal place of business is in Odessa.  Sonic furnishes specialized rental equipment and tools to the oil and gas industry in West Texas.  The general partner of Sonic is Lonnie’s Well Service Co.; both parties will be referred to as Sonic.

According to its annual report, Superior manufactures, sells, and rents specialized equipment used in offshore and onshore oil and gas drilling.  One of Superior’s four business segments is its rental tool segment.  Superior’s rental tool segment has locations in “all of the major staging points in Louisiana and Texas for oil and gas activities.”  Blowout Tools, Inc. (BTI) is a subsidiary of Wild Well Control, Inc. (Wild Well); BTI and Wild Well are part of the rental tool segment.  Wild Well is a subsidiary of SESI, which is owned by Superior.  Superior also owns a subsidiary named Superior Energy Services, L.L.C., that has extensive operations in Texas.

BTI, Wild Well, Superior, and SESI wanted to expand BTI’s and Wild Well’s oilfield equipment rental business in West Texas.  Westy Ballard, an employee of SESI, called Jackie Manning to see if the partners of Sonic had an interest in selling Sonic.  After Manning indicated they had no interest, BTI hired Shoemaker.  Superior funded the new business with $3.6 million.

In the underlying lawsuit to this appeal, Sonic sued Shoemaker, BTI, Wild Well, SESI, Superior Energy Services, L.L.C., and Superior.  Superior and SESI entered special appearances, which, after an evidentiary hearing, were overruled by the trial court.  In this appeal, Superior and SESI argue that the only rationale for exercising jurisdiction over a parent corporation is if the parent corporation exercises such control and dominance over its subsidiary that they are in reality one and the same corporation for purposes of jurisdiction.  BMC Software Belgium, N.V. v. Marchand, 83 S.W.3d 789, 798 (Tex. 2002).  Relying on that principle, Superior and SESI argue that there is no evidence that Superior and SESI exercise such control and dominance over BTI and Wild Well.

Sonic contends that the control argument made by Superior and SESI is not relevant.  Sonic asserts that its claims against Superior and SESI are based on their own operations in Texas and their actions in facilitating Shoemaker’s alleged breach of his partnership agreement with Sonic and his breach of fiduciary duties to Sonic.  Sonic also asserts claims against Superior and SESI for tortious interference with contract and business relations, for misappropriation and theft of trade secrets and proprietary business information, for unjust enrichment, and for liability as principals and being part of a conspiracy.

Law

Texas courts have personal jurisdiction over a nonresident defendant when (1) the Texas long-arm statute provides for it and (2) the exercise of jurisdiction is consistent with federal and state due process guarantees.  Spir Star Ag v. Kimich, 310 S.W.3d 868, 872 (Tex. 2010); Am. Type Culture Collection, Inc. v. Coleman, 83 S.W.3d 801, 806 (Tex. 2002).  The long-arm statute reaches “as far as the federal constitutional requirements of due process will allow.”  Guardian Royal Exch. Assurance, Ltd. v. English China Clays, P.L.C., 815 S.W.2d 223, 226 (Tex. 1991).

Personal jurisdiction over nonresident defendants is constitutional only when (1) the defendant has established minimum contacts with the forum state and (2) the exercise of jurisdiction comports with traditional notions of fair play and substantial justice.  Int’l Shoe Co. v. State of Washington, Office of Unemployment Comp. & Placement, 326 U.S. 310, 316 (1945).  A defendant’s contacts with a forum can give rise to either specific or general jurisdiction.  Spir Star Ag, 310 S.W.3d at 872; CSR Ltd. v. Link, 925 S.W.2d 591, 595 (Tex. 1996).  General jurisdiction exists when a defendant’s contacts are continuous and systematic, even if the cause of action did not arise from activities performed in the forum state.  Specific jurisdiction exists when the alleged liability arises from or is related to the defendant’s activities conducted within the forum.  CSR Ltd., 925 S.W.2d at 595.

The trial court held an evidentiary hearing on the special appearance motions of Superior and SESI.  Because the trial court made no findings in this case, all facts necessary to support the trial court’s judgment are implied.  Worford v. Stamper, 801 S.W.2d 108, 109 (Tex. 1990).  Superior and SESI have challenged the sufficiency of the evidence; therefore, the standard of review to be applied is the same as that to be applied in the review of jury findings or a trial court’s findings of fact.  Daimler-Benz Aktiengesellschaft v. Olson, 21 S.W.3d 707, 715 (Tex. App.—Austin 2000, pet. dism’d w.o.j.).

                                                                  Issue on Appeal

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Superior Energy Services, Inc. and SESI, LLC v. Sonic Petroleum Services, Ltd. and Lonnie's Well Service Co., General Partner, Counsel Stack Legal Research, https://law.counselstack.com/opinion/superior-energy-services-inc-and-sesi-llc-v-sonic--texapp-2010.