Valence Operating Company v. Anadarko Petroleum Corporation

CourtCourt of Appeals of Texas
DecidedJanuary 15, 2010
Docket06-09-00023-CV
StatusPublished

This text of Valence Operating Company v. Anadarko Petroleum Corporation (Valence Operating Company v. Anadarko Petroleum Corporation) 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
Valence Operating Company v. Anadarko Petroleum Corporation, (Tex. Ct. App. 2010).

Opinion



In The

Court of Appeals

Sixth Appellate District of Texas at Texarkana



______________________________



No. 06-09-00023-CV



VALENCE OPERATING COMPANY, Appellant



V.



ANADARKO PETROLEUM CORPORATION, Appellee





On Appeal from the Fourth Judicial District Court

Rusk County, Texas

Trial Court No. 2001-032





Before Morriss, C.J., Carter and Cornelius,* JJ.

Opinion by Justice Cornelius



________________________

*William J. Cornelius, Chief Justice, Retired, Sitting by Assignment



O P I N I O N



This case involves the interpretation of a nonconsent provision in a joint operating agreement to develop oil and gas leases. Although the case presents many issues, the principal question is whether Valence Operating Company (Valence) actually commenced work on its proposed operation to drill four wells within the time frame specified by a joint operating agreement.

Valence entered into a joint operating agreement with Anadarko Petroleum Corporation's (Anadarko) predecessor, Union Pacific Resources Company to develop oil and gas leases in the Ballow Estate Gas Unit No. 1 in Rusk County. Anadarko, which owned a 65.62 percent working interest in the unit, was designated Operator in the Joint Operating Agreement. Valence was a nonoperator, owning an approximate twenty-one percent interest.

Pursuant to Article VI of the Joint Operating Agreement, Valence proposed to drill four wells in the unit. As a nonoperator, Valence's proposal to drill the wells was specifically covered by Article VI.B.1 and 2, which provided:

1. Proposed operations:

Should any party hereto desire to drill any well on the Contract Area other than the (initially proposed well contemplated by the agreement) . . . the party desiring to drill, rework, deepen, or plug back such a well shall give the other parties written notice of the proposed operation, specifying the work to be performed, the location, proposed depth, objective formation and the estimated cost of the operation. The parties receiving such a notice shall have thirty (30) days after receipt of the notice within which to notify the parties wishing to do the work whether they elect to participate in the cost of the proposed operation. Failure of a party receiving such notice to reply within the period above fixed shall constitute an election by that party not to participate in the cost of the proposed operation.

2. Operations by Less than All Parties:

If any party receiving such notice elects not to participate in the proposed operation, then, in order to be entitled to the benefits of this article, the party or parties giving the notice and such other parties as shall elect to participate in the operation shall, within sixty (60) days after the expiration of the notice period of thirty (30) days actually commence work on the proposed operation, and complete it with due diligence.



The Joint Operating Agreement also provided that

[t]itle examination shall be made on the drill site of any proposed well prior to commencement of drilling operations . . . . No well shall be drilled on the Contract Area until after (1) the title to the drill site has been examined as above provided, and (2) the title has been approved by the examining attorney or title has been accepted by all of the parties who are to participate in the drilling of the well.



Pursuant to Article VI.B.1, Valence sent a letter to Anadarko on December 14, 1999, proposing "immediate drilling" of four wells in the contract area. Anadarko received the letter on December 17. Valence gave Anadarko thirty days from its receipt of the letter to consent to the project. Because the cost of the proposed project is only borne by consenting parties, a nonconsenting party relinquishes its interest to consenting parties for a period of time. Also, a nonconsenting party does not enjoy the revenue from a proposed project until all consenting parties have recovered their costs, along with an additional portion of revenue to compensate them for the risks  taken  in  investing  in  the  project.  Anadarko  did  not  consent.  Therefore,  as  prescribed by Article VI.B.2, Valence became the operator for the purposes of its proposal, and was mandated to "actually commence work on the proposed operation" by March 17, 2000. Once the project began, Valence was required to "complete it with due diligence" in order to reap the benefits of Anadarko's nonconsent status. When the deadline passed, Anadarko brought suit against Valence for breach of contract, negligence, declaratory judgment, quantum meruit, unjust enrichment, conversion, and an accounting, alleging that Valence failed to perform its obligation  to  actually  commence  operations  for  drilling  the  proposed  wells  before March 17, 2000.

Both Valence and Anadarko contended at trial that the issue of Valence's compliance with the requirement of Article VI.B.2 that Valence "actually commence work on the proposed operation" by the prescribed deadline and "complete it with due diligence" was a question of law. The trial court, however, concluded that the issue was not established as a matter of law and submitted the issue to the jury by the following question:

As to each of the wells in question, did Valence fail to comply with the provision of Article VI. B. 2 of the Operating Agreement which states that "the party or parties giving the notice and such other parties as shall elect to participate in the operation shall, within sixty (60) days after the expiration of the notice period of thirty (30) days . . . actually commence work on the proposed operation and complete it with diligence?"



The jury answered "yes" as to each well. The trial court rendered judgment for Anadarko on the jury verdict for actual damages, attorneys' fees, and prejudgment interest.

Valence raises fifteen issues on appeal, which we group for discussion as follows:

I. Whether as a matter of law, Valence actually commenced work on the proposed operation before the deadline and completed it with due diligence? (Issues 1, 2, 3, and 4); II. The trial court's failure to give certain instructions and definitions to the jury. (Issues 6, 7, 8, 9, 10, 11, and 12); III. There is insufficient evidence to support the jury's verdict. (Issue 14); IV. The trial court's failure to exclude Owen Barnhill's testimony as to the generally accepted meaning of "commencement of operations" in the oil and gas industry. (Issue 5); V. The trial court's failure to dismiss Anadarko's suit for want of prosecution. (Issue 15); VI. The trial court's alleged error in awarding Anadarko prejudgment interest. (Issue 13). For the reasons set out hereafter, we overrule all these issues and affirm the trial court's judgment.

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Valence Operating Company v. Anadarko Petroleum Corporation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/valence-operating-company-v-anadarko-petroleum-cor-texapp-2010.