Transtexas Gas Corp, N/K/A Sandridge Onshore, Llc v. Forcenergy Onshore, Inc.

CourtCourt of Appeals of Texas
DecidedApril 12, 2012
Docket13-10-00446-CV
StatusPublished

This text of Transtexas Gas Corp, N/K/A Sandridge Onshore, Llc v. Forcenergy Onshore, Inc. (Transtexas Gas Corp, N/K/A Sandridge Onshore, Llc v. Forcenergy Onshore, Inc.) 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.

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Transtexas Gas Corp, N/K/A Sandridge Onshore, Llc v. Forcenergy Onshore, Inc., (Tex. Ct. App. 2012).

Opinion

NUMBER 13-10-00446-CV

COURT OF APPEALS

THIRTEENTH DISTRICT OF TEXAS

CORPUS CHRISTI - EDINBURG

TRANSTEXAS GAS CORP., N/K/A SANDRIDGE ONSHORE, LLC, Appellant,

v.

FORCENERGY ONSHORE, INC., Appellee.

On appeal from the 329th District Court of Wharton County, Texas.

MEMORANDUM OPINION Before Justices Garza, Benavides, and Vela Memorandum Opinion by Justice Vela This is an appeal from a judgment in a non-jury case granting declaratory relief and

attorney's fees in favor of Forcenergy Onshore, Inc. ("Forcenergy"). Appellant,

TransTexas Gas Corp. n/k/a SandRidge Onshore LLC ("TransTexas"), raises nine issues on appeal, complaining that the trial court erred in re-adjudicating its title in the relevant oil

and gas leasehold estate because title was adjudicated in a prior suit between the same

parties. TransTexas also urges that the trial court erred by: (1) declaring that

Forcenergy owns fee simple determinable and TransTexas owns the possibility of a

reverter; (2) declaring that the title to TransTexas's working interest is reduced by the

operation of the non-consent provision set forth in a September 1982 joint operating

agreement; (3) concluding that Forcenergy prevailed in the prior litigation between the

parties in connection with the issue of the application of the joint operating agreements to

TransTexas; (4) concluding that TransTexas did not preserve the issue of the application

of the joint operating agreements to TransTexas in the appeal of the prior case between

the parties; (5) declaring that the September 1982 joint operating agreement acted to

convey title from TransTexas to Forcenergy to the "fee simple determinable" in all of

TransTexas's working interest; (6) declaring that Forcenergy could enforce the

September 1982 joint operating agreement against TransTexas despite the fact that the

joint operating agreement was an executory contract rejected in TransTexas's

bankruptcy; (7) failing to award TransTexas the relief it requested; and (8) awarding

Forcenergy attorney's fees. We affirm.

I. BACKGROUND

A. Stipulated Evidence

This is a suit between two oil and gas companies involving contract claims. The

claims involve the rights of the parties with respect to an oil and gas lease called the

Krueger Lease. The parties entered into a lengthy stipulation of facts in the trial court.

2 Among the stipulated facts was an agreement that TransTexas and Forcenergy's

leasehold interests in the Krueger Lease are held under chains of title that originated from

Nasco, Ltd. ("Nasco") and Kimbark Oil and Gas Company Ltd. ("Kimbark"). Thereafter,

Kimbark, Roy H. Dubitzky & Associates ("Dubitzky") and Nasco as non-operators, and

Forney Oil Corporation ("Forney") as operator, who collectively owned 100% of the

leasehold interest in the Krueger Lease, entered into a letter agreement dated September

22, 1982, and a joint operating agreement, which covered all of the leasehold interest in

the Krueger Lease. Subsequently, Nasco made assignments of its retained 12.5%

leasehold interest and Kimbark's 87.5% leasehold interest, which were made expressly

subject to the September 1982 joint operating agreement and the assignments were filed

in the real property records.

The parties disagree with respect to whether they obtained their respective

interests in the Krueger Lease subject to a September 1982 joint operating agreement.

But, they agreed that Forney and others as non-operators, and Bill Forney, Inc., as

operator, entered into a joint operating agreement, dated October 8, 1982, which covered

their interests in the Krueger Lease. At issue here is the applicability of the non-consent

provision of the September 1982 joint operating agreement providing that upon drilling,

reworking, deepening or plugging any well, that each non-consenting party "shall be

deemed to have relinquished to Consenting parties all of such Non-Consenting Party's

share of the costs of any new surface equipment and operation of the well, and (b) up to

300% of the Non-Consenting party's share of the costs and expenses of drilling and new

equipment in the well, subject to deductions."

3 In 1984, the majority of the working interest owners in the Deep Rights1 conveyed

their interests to Conoco, Inc. ("Conoco"). However, Arrington and Dubitzky did not.

Forcenergy's working interest in the Deep Rights derives from two assignments conveyed

by Arrington and Dubitzky in 1986, which collectively conveyed 2.8125% of the working

interest. Arrington and Dubitzky obtained their respective interests in the Krueger Lease

expressly subject to the September 1982 joint operating agreement. Arrington and

Dubitzky assigned part of their remaining working interest in the Deep Rights to

TransTexas, being .9375%, conveyed in 1998.

In the first case that came before this Court, Forcenergy challenged TransTexas's

ownership rights in a portion of the Deep Rights to the Krueger Lease, claiming that those

rights were never obtained by Conoco and TransTexas as an assignee of Conoco.

TransTexas Gas Corp. v. Forcenergy Onshore, Inc., 13-02-387-CV, 2004 WL 1901717,

at *1 (Tex. App.—Corpus Christi Aug. 26, 2004, pet. denied) (mem. op.) (TransTexas I).

During the pendency of the initial case, Forcenergy sent drilling proposals to TransTexas,

seeking consent to its proposed drilling in the Deep Rights, including wells known as the

Krueger 8, 9, 10 and 12. Id. at *1. TransTexas does not contest that the four drilling

proposals contained all of the information required to be furnished under the September

joint operating agreement, but contests that the September joint operating agreement

applies to it.

TransTexas responded to Forcenergy's drilling proposals by stating that it did not

believe that the proposals were proper and TransTexas did not consent. TransTexas

1 The parties have referred to the zone below 8,500 feet as the "Deep Rights", and the zone above that depth as the "Shallow Rights". 4 contends it is not to be bound by the September and October joint operating agreement

and its interests in the Krueger Lease are not subject to those agreements. Forcenergy

counters that TransTexas's interest in the Krueger Lease is subject to the September joint

operating agreement and it is entitled to the non-consent recoveries provided in the joint

operating agreement.

In November 2002 the Krueger wells were completed. TransTexas filed

bankruptcy under Chapter 11 of the Bankruptcy Code. Forcenergy filed a proof of claim

in January 2003.

The parties agreed that the initial case was severed from this one by order dated

April 2, 2002. In TransTexas I, the trial court ruled in favor of Forcenergy on issues

relating to the Krueger Lease. This Court reversed and ruled primarily in favor of

TransTexas, which now urges that our original opinion included a finding that the

September and October joint operating agreements are inapplicable to it. Forcenergy

contends that this Court found that the joint operating agreements were applicable to

TransTexas, but acknowledges that this Court's opinion determined that Forcenergy was

not the operator. Forcenergy argues that the September joint operating agreement

applied to TransTexas and that Forcenergy, as the owner of what it contends are

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Transtexas Gas Corp, N/K/A Sandridge Onshore, Llc v. Forcenergy Onshore, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/transtexas-gas-corp-nka-sandridge-onshore-llc-v-fo-texapp-2012.