Venable's Construction, Inc v. Aspen Midstream, LLC

CourtTexas Court of Appeals, 1st District (Houston)
DecidedDecember 31, 2025
Docket01-24-00702-CV
StatusPublished

This text of Venable's Construction, Inc v. Aspen Midstream, LLC (Venable's Construction, Inc v. Aspen Midstream, LLC) is published on Counsel Stack Legal Research, covering Texas Court of Appeals, 1st District (Houston) primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Venable's Construction, Inc v. Aspen Midstream, LLC, (Tex. Ct. App. 2025).

Opinion

Opinion issued December 31, 2025

In The

Court of Appeals For The

First District of Texas ———————————— NO. 01-24-00702-CV ——————————— VENABLE’S CONSTRUCTION, INC., Appellant/Cross-Appellee V. ASPEN MIDSTREAM, LLC, Appellee/Cross-Appellant

On Appeal from the 113th District Court Harris County, Texas Trial Court Case No. 2022-28820

OPINION

This construction contract case presents a classic disagreement about pricing.

A pipeline company (Aspen) hired a contractor (Venable’s) to build some 56 miles

of 30-inch pipeline from a site in Washington County to a site in Waller County. The contract set the lump sum price at about $39 million. The contract plainly has some

fixed price provisions, with phrases like “Lump Sum,” “absolute cap,” and “not in

addition to the Lump Sum price.” But the contract just as plainly contains provisions

for extra work, change orders, and unit prices for such additional work.

How much was Aspen required to pay Venable’s? Venable’s took the position

that the project ended up requiring additional footages and efforts beyond what the

$39 million lump sum contemplated, so Aspen owed it another $1.77 million. Aspen

disagreed about owing the additional amount. This lawsuit followed.

On cross-motions for summary judgment, the trial court sided with Aspen.

First, the court rejected the claim for additional compensation. Second, the court

agreed with Aspen that Venable’s owes a duty to defend an Aspen affiliate in a suit

by some Waller County landowners who say the project left the topsoil in disarray

and hurt their rice farming. We agree with Aspen about the price issue, but we

disagree about the duty to defend Aspen’s own affiliate. We therefore do not reach

Aspen’s conditional cross-appeal concerning objections it made to some of the

summary judgment evidence filed by Venable’s.

We affirm in part, reverse in part, and remand the issue of attorney’s fees

under the Declaratory Judgments Act for further proceedings.

2 Background

A. Contractual Relationship Between Aspen and Venable’s

In 2018, Aspen decided to install a new pipeline approximately 56 miles in

length from Washington County to Waller County. It sought bids from contractors

and ultimately accepted the bid from Venable’s. In 2019, they signed a written

“Master Construction Agreement.”

This contract calls for Venable’s to do what it calls the “Work” in exchange

for a “Lump Sum,” but it does considerably more than that. The contract consists of

several parts, dozens of sections, and a variety of exhibits.

Part I (“General Terms, Understandings and Obligations of the Parties”) runs

3 pages in length and says that Venable’s shall perform the Work for a Lump Sum

of $39,335,430.35. Part II (“Specific Terms and Conditions”) runs 24 pages in length

and has 45 sections. Part III (“Instructions and Information to Bidder”) deals with

the bid process and items such as insurance. Part IV (“Contractor Firm Offer”) has

two subparts:

• Subpart A, entitled “Lump Sum Price,” and

• Subpart B, entitled “Special Unit Prices.”

First, the Lump Sum Price in Subpart A reiterates the $39 million figure stated earlier

in the contract. Second, the Special Unit Prices in Subpart B provide prices “For

Extra Work Only.” That is, in the event of “Extra Work,” the Special Unit Prices

3 “shall be used in the event Contractor is required to supply and install Special Unit

Items during the execution of Extra Work, pursuant to a change order authorized

under Section 11 of Part II of the Agreement.” Having briefly described the four

parts of the contract, we will examine those parts in greater detail before beginning

the legal analysis.

1. Contract: Part I

Part I of the contract calls for Venable’s to perform the agreed-upon Work

and for Aspen to pay Venable’s the agreed-upon price. Part 1, section 1 speaks in

terms of the “Work described in Exhibit ‘A’” but does not define the Work in any

further detail. Exhibit A (“Scope of Work”) appears later in the agreement.

Part I also contains a price term in section 5:

Price. As total consideration for the Work to be performed hereunder, Company shall pay Contractor a total sum of 39,335,430.35 Dollars ($39,335,430.35) (“Lump Sum”)[.] Under no circumstances shall Company be obligated to compensate Contractor beyond the Lump Sum amount set forth in this Part I, Section 5 and the Work Offer attached hereto as Exhibit F.

Section 5 continues by stating that it takes precedence over any conflicting language

elsewhere in the contract: “In the event of conflict in the terms of this Part I, Section

5 and any other Part(s) or Exhibits to this Agreement, this Part I Section 5 shall

control and be decisive of the issue.”

4 2. Contract: Part II

Part II, section 1 lists definitions. It defines “Work” as follows: “‘Work’ as

used herein shall mean the doing of all things described in the Scope of Work defined

in Part I all in accordance with the terms, conditions, and standards of the Agreement

as well as any other additional things as may be necessary to achieve the intent of

this Agreement in a timely manner.”

Section 6 (“Representations and Warranties”) contains a representation by

Venable’s about the price:

Contractor’s Lump Sum price, as set forth in Section 5 of Part I, is an absolute cap irrespective of any occurrence, error or omissions in drawings or specifications, post agreement increases in materials, delay for right of entry or delivery of materials, any deviations between the issued for bid and/or issued for construction drawings and specifications, hindrance or other cause known or unknown . . . in the amount it will be compensated for completion of the Work hereunder.

Venable’s further represents that “under this Lump Sum Agreement, it is assuming

all risk associated with the Work and that Contractor’s costs to assume such risk are

included and reflected in its Lump Sum Price.”

Section 11 (“Extra Work – Changes”) provides for additional work “which

arises outside and is independent or not otherwise included in this Agreement or its

scope (hereinafter referred to as ‘Extra Work’).” Extra Work “may be occasioned by

major changes in design or specification regarding Work of both a materially

different nature and cost from that contemplated at the time of execution of this

5 Agreement, or the performance of other or additional Work incident to the

completion of the project or facilities here involved, but not in contemplation of the

parties at the time of execution of this Agreement.”

Section 11 spells out what will not qualify as Extra Work:

Notwithstanding anything contained herein to the contrary, Contractor agrees that any change in the amount of materials or Work of any kind or character as described in Part IV Subparts A and B of this Agreement shall not constitute Extra Work and are included within and not in addition to the Lump Sum price as set forth in Part I, Section 5 of this Agreement.

Section 19 deals with indemnity. As a result, many of its provisions come in

bolded capital letters to make them conspicuous, even if not especially easy to read.

Among other things, this section provides that Venable’s will indemnify, defend,

release, and hold harmless Aspen (plus its parent, affiliates, partners, agents, and

employees) from any claims alleged to arise out of any breach of the contract by

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Venable's Construction, Inc v. Aspen Midstream, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/venables-construction-inc-v-aspen-midstream-llc-txctapp1-2025.