Taylor, H. B., Jr. v. Brigham Oil & Gas, L. P., Brigham Land Management, Veritas Gephysical, LTD.

CourtCourt of Appeals of Texas
DecidedJanuary 16, 2002
Docket07-00-00225-CV
StatusPublished

This text of Taylor, H. B., Jr. v. Brigham Oil & Gas, L. P., Brigham Land Management, Veritas Gephysical, LTD. (Taylor, H. B., Jr. v. Brigham Oil & Gas, L. P., Brigham Land Management, Veritas Gephysical, LTD.) 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
Taylor, H. B., Jr. v. Brigham Oil & Gas, L. P., Brigham Land Management, Veritas Gephysical, LTD., (Tex. Ct. App. 2002).

Opinion

TAYLOR V BRIGHAM
NO. 07-00-0225-CV


IN THE COURT OF APPEALS


FOR THE SEVENTH DISTRICT OF TEXAS


AT AMARILLO


PANEL D


JANUARY 16, 2002

______________________________


H.B. TAYLOR, JR
,



Appellant

v.


BRIGHAM OIL & GAS, L.P.,

BRIGHAM LAND MANAGEMENT,

and VERITAS GEOPHYSICAL, LTD.,



Appellees
_________________________________


FROM THE 31ST DISTRICT COURT FOR WHEELER COUNTY;


NO. 10,341; HON. STEVEN R. EMMERT, PRESIDING
_______________________________


Before BOYD, C.J., QUINN and REAVIS, JJ.

H.B. Taylor, Jr. (Taylor), appeals from a final summary judgment entered in favor of Brigham Oil and Gas, L.P., and Brigham Land Management (collectively referred to as Brigham) and Veritas Geophysical, Ltd. (Veritas). The dispute arose from entry by Veritas onto land, the surface of which Taylor owned. Veritas so entered the premises to conduct seismic exploration on behalf of Brigham. The three points of error before us involve 1) the authority to enter upon the lands, 2) unreasonably exceeding the extent of the permission or the commission of negligence once entry was gained, and 3) punitive damages. (1) We affirm the judgment.

Background

Brigham and Veritas sued Taylor for declaratory and injunctive relief. Taylor had leased the land in question for mineral exploration. Brigham obtained permission from a minority working interest owner to conduct seismic exploration upon the property and engaged Veritas to perform the work. However, Taylor refused them entry, threatening to meet them with a shotgun. Thus, Brigham and Veritas sued.

Upon joining issue, Taylor counterclaimed for damages. By that time, Veritas had entered upon the realty and conducted the operations desired. According to Taylor, however, the exploration encroached upon more of the surface than was reasonably necessary. So too did Taylor allege that Veritas not only negligently damaged portions of the surface estate but did so with malice. Brigham and Veritas subsequently moved for summary judgment, contending that 1) it had a right to enter the property to conduct seismic operations and 2) Taylor had no evidence evincing that they breached any duty owed him or acted with malice. The trial court agreed, granted the motion, and entered summary judgment in favor of Brigham and Veritas.

Points One and Two

Though Taylor contended below that neither Brigham nor Veritas had permission to enter, he modifies his argument on appeal. Through point one, he now posits that the extent of their authority did not include the right to traverse the surface estate more than was reasonably necessary or to negligently damage the surface estate. (2) Moreover, his second point covers the same subject. That is, through it, he believes that he presented sufficient evidence to create an issue of fact regarding whether the entities acted unreasonably. Given the similarity between the two issues, we address them together and, upon doing so, overrule them.

Standard of Review

The standard of review applicable to no evidence summary judgments is well-settled. We find it sufficient to merely cite the litigants to Kimber v. Sideris, 8 S.W.3d 672, 675 (Tex. App. - Amarillo 1999, no pet.).

Furthermore, to the extent that one has a right to enter upon the surface estate to explore for oil and gas, the right is not necessarily absolute. Unless the parties agree otherwise, the entity performing the exploration may not commit negligence nor use more of the surface than reasonably necessary. Humble Oil & Refining Co. v. Williams, 420 S.W.2d 133, 134 (Tex. 1967); Oryx Energy Co. v. Shelton, 942 S.W.2d 637, 641 (Tex App.--Tyler 1996, no writ). Yet, evidence that damage occurred to the surface while exploring for minerals alone is not evidence of negligence or unreasonably excessive use. This is so because of the nature of the estates involved and the correlative rights and liabilities accompanying them.

The execution of a mineral lease not only severs the minerals from the surface but also creates dominant and servient estates. The entity that owns the minerals enjoys the dominant estate. Tarrant County Water Control & Improv. Dist. v. Haupt, Inc., 854 S.W.2d 909, 911 (Tex. 1993) (stating that the mineral estate is the dominant estate). Furthermore, ownership of the dominant estate carries with it the right to enter and extract the minerals and "all other such incidents thereto as are necessary to be used for getting and enjoying" the minerals. Id. And, incident to the right to extract is the right to explore. Id. More importantly, if in pursuing these rights, the servient estate is susceptible to use in only one manner, then the owner of the dominant estate may pursue that use irrespective of whether it results in damage to the surface. Id.; Getty Oil Co. v. Jones, 470 S.W.2d 618, 622 (Tex. 1971). In other words, if particular damage to the surface estate cannot reasonably be avoided in legitimately pursuing the rights of the dominant estate, the owner of the dominant estate is not liable for the damage.

Thus, the mere fact of damage to the surface does not evince unreasonable conduct. See Ball v. Dillard, 602 S.W.2d 521, 523 (Tex. 1980). Instead, it is encumbent upon the surface owner to establish that the dominant estate owner failed to use reasonable care in pursuing its rights or that the rights could have been pursued through reasonable alternate means sufficient to achieve the goal desired but without the damage. Tarrant County Water Control & Improv. Dist. v. Haupt, Inc., 854 S.W.2d at 91. Simply put, the servient estate owner must prove that its opponent failed to act reasonably given the correlative rights and liabilities involved.



Application of Standard

Here, Taylor alleges that Brigham and Veritas were unreasonable in the manner in which they performed the seismic work. This is allegedly so because in using the equipment they did (vibraseisors) and the manner in which they used it, they purportedly traversed 16 miles of surface land as opposed to four, drove over the contours of each canyon, removed or damaged 75 to 80 feet of fencing, created "unordinary ruts," cut grass and other plant life off of hillsides which caused "[c]onsiderable erosion," and "cut the top off" of hills 'they had gone up.'" Additionally, the damage caused by this round of seismic exploration was greater than that caused previously, according to Taylor.

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

Related

Rowe v. Robert Half International, Inc.
544 U.S. 1051 (Supreme Court, 2005)
Roberts v. Texas
128 S. Ct. 282 (Supreme Court, 2007)
Hart v. State
173 S.W.3d 131 (Court of Appeals of Texas, 2005)
Drichas v. State
175 S.W.3d 795 (Court of Criminal Appeals of Texas, 2005)
Dyar v. State
125 S.W.3d 460 (Court of Criminal Appeals of Texas, 2003)
Watson v. State
204 S.W.3d 404 (Court of Criminal Appeals of Texas, 2006)
Hooper v. State
214 S.W.3d 9 (Court of Criminal Appeals of Texas, 2007)
Dhillon v. State
138 S.W.3d 583 (Court of Appeals of Texas, 2004)
Carmouche v. State
10 S.W.3d 323 (Court of Criminal Appeals of Texas, 2000)
Ball v. Dillard
602 S.W.2d 521 (Texas Supreme Court, 1980)
Armendariz v. State
123 S.W.3d 401 (Court of Criminal Appeals of Texas, 2003)
Woods v. State
152 S.W.3d 105 (Court of Criminal Appeals of Texas, 2004)
Humble Oil & Refining Company v. Williams
420 S.W.2d 133 (Texas Supreme Court, 1967)
Sandoval v. State
35 S.W.3d 763 (Court of Appeals of Texas, 2001)
Gallups v. State
151 S.W.3d 196 (Court of Criminal Appeals of Texas, 2004)
Lunde v. State
736 S.W.2d 665 (Court of Criminal Appeals of Texas, 1987)
Peddicord v. State
942 S.W.2d 100 (Court of Appeals of Texas, 1997)
Oryx Energy Co. v. Shelton
942 S.W.2d 637 (Court of Appeals of Texas, 1996)
Warrick v. State
634 S.W.2d 707 (Court of Criminal Appeals of Texas, 1982)
Thacker v. State
889 S.W.2d 380 (Court of Appeals of Texas, 1994)

Cite This Page — Counsel Stack

Bluebook (online)
Taylor, H. B., Jr. v. Brigham Oil & Gas, L. P., Brigham Land Management, Veritas Gephysical, LTD., Counsel Stack Legal Research, https://law.counselstack.com/opinion/taylor-h-b-jr-v-brigham-oil-gas-l-p-brigham-land-m-texapp-2002.