Transtexas Gas Corporation v. Forcenergy Onshore, Inc.

CourtCourt of Appeals of Texas
DecidedAugust 26, 2004
Docket13-02-00387-CV
StatusPublished

This text of Transtexas Gas Corporation v. Forcenergy Onshore, Inc. (Transtexas Gas Corporation 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 Corporation v. Forcenergy Onshore, Inc., (Tex. Ct. App. 2004).

Opinion




NUMBER 13-02-387-CV


COURT OF APPEALS


THIRTEENTH DISTRICT OF TEXAS


CORPUS CHRISTI - EDINBURG





TRANSTEXAS GAS CORPORATION,                                         Appellant,


v.


FORCENERGY ONSHORE, INC.,                                                 Appellee.





On appeal from the 329th District Court

of Wharton County, Texas.





MEMORANDUM OPINION


Before Justices Rodriguez, Castillo, and Wittig


Memorandum Opinion by Justice Castillo


         This is an action to quiet title between two successors in interest to an oil and gas interest. Appellee Forcenergy Onshore, Inc. ("Forcenergy") brought suit against appellant TransTexas Gas Corporation ("TransTexas") to remove a cloud on Forcenergy's title. By five issues, TransTexas contends the trial court committed error: (1) in granting Forcenergy's motion for summary judgment that Forcenergy holds title to the disputed mineral interest; (2) in refusing to grant TransTexas's motion for summary judgment that TransTexas holds title to the disputed mineral interest; (3) by declaring that Forcenergy is the operator of the mineral interests at issue; (4) in refusing to grant TransTexas's motion for summary judgment on the operatorship issue; and (5) by awarding Forcenergy attorney fees under the Uniform Declaratory Judgments Act (the "UDJA"). We reverse and render in part and remand in part.

I. RELEVANT FACTS

         This is a memorandum opinion. The parties are familiar with the facts. We will not recite them here except as necessary to advise the parties of our decision and the basic reasons for it. See Tex. R. App. P. 47.4.

         At the heart of the parties' dispute are three related documents: (1) a "Letter Exchange Agreement" dated September 18, 1984; (2) a "Farmout Agreement" dated September 14, 1984; and (3) an "Assignment of Oil, Gas, and Mineral Lease" dated

October 10, 1984. The three documents memorialized an earlier agreement between TransTexas and Forcenergy's predecessors in interest to exchange assignments of equivalent mineral rights and for Forcenergy to farm out other lease interests to TransTexas. In the Letter Exchange Agreement, Forcenergy agreed to trade its deep rights (those minerals at a depth of more than 8,500 feet) in one leasehold for TransTexas's shallow rights in another leasehold. At issue is title to the deep mineral rights subject to the Letter Exchange Agreement.

A. The Parties' Agreements

1. The Letter Exchange Agreement

         The Letter Exchange Agreement stated that it "shall evidence the agreement made as of September 7, 1984 between [Forcenergy] and [TransTexas] relative to lands in Wharton County, Texas." It was not filed of record. It provided in relevant part:

[Forcenergy] and [TransTexas] agree to exchange assignments covering certain interests over certain lands on the following terms and conditions.

I. [Forcenergy] Assignments:

A.[Forcenergy] agrees to assign or cause to be assigned to [TransTexas] the following interests in the following leases insofar and only insofar as said leases cover depths below 8500':

1)An 83.75% Working Interest in and to those leases colored red on the attached plat.

2)83.75% of 75% Working Interest in and to those leases colored blue on the attached plat.

3)100% Working Interest in and to those leases colored green on the attached plat.


* * *

C.It is hereby understood and agreed that [TransTexas] must reassign to [Forcenergy] any and all acreage which has not been allocated to a producing or proration unit, as prescribed or permitted by the State of Texas, or included within a pooled unit, whichever is larger, within 3 years from the date of the assignment. However, should [TransTexas] establish production below 8500 feet within the area outlined in red on the attached plat within 3 years from the date of the assignment, then this 3 year period shall be automatically extended for an additional 2 years.


II.[TransTexas] Assignments:

A. [TransTexas] agrees to assign to [Forcenergy] all of its right, title and interest in and to those lands colored yellow on the attached plat insofar and only insofar as said leases cover depths from the surface of the earth to 8500 feet. . . .

B.It is agreed to by the parties hereto that [Forcenergy] will reassign to [TransTexas] any and all acreage assigned to [Forcenergy] which has not been allocated to a pooled or proration unit, whichever is larger within 3 years from the date of the assignment or on or before 60 days prior to the expiration of the assigned lease(s), whichever occurs first.


         2. The Farmout Agreement

         Like the Letter Exchange Agreement, the Farmout Agreement also stated that it "shall evidence the general terms of the agreement made September 7, 1984 between [Forcenergy] and [TransTexas] relative to lands in Wharton County, Texas." Like the Letter Exchange Agreement, the Farmout Agreement was not recorded of record. It provided in relevant part:

[TransTexas] agrees to farmout to [Forcenergy] all of its right, title and interest in and to the leases within the Areas designated as Areas I, II and III on the attached plat under the following general terms:

6)[Forcenergy] shall have the right and option to earn either one or both of the remaining undrilled Areas by timely commencing a Test Well (Option Well), and completing the same as a well capable of commercial production, on each of the then undrilled Areas in the same manner and to the same objective depth as the Initial Test Well. [Forcenergy's] option to earn shall terminate unless the first well drilled on each Area is spudded within 180 days from completion, either as a dry hole or as a producer, of the first Test Well (or Successive Well) on the previously drilled block. [Forcenergy] shall earn and Conoco shall retain the same rights as set out under the Initial Test Well above with respect to each additional Area.


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