XTO Energy Inc. v. Smith Production Inc.

Procedural entryThis page is a short order in XTO Energy Inc. v. Smith Production Inc.. Read the opinion of the Court — 2009 Tex. App. LEXIS 1238
Court of Appeals of Texas·Decided February 24, 2009·No. 14-07-00069-CV·Published

Opinion

Affirmed and Majority and Dissenting Opinions filed February 24, 2009

Affirmed and Majority and Dissenting Opinions filed February 24, 2009.

In The

Fourteenth Court of Appeals

____________

NO. 14-07-00069-CV

XTO ENERGY INC., Appellant

V.

SMITH PRODUCTION INC., Appellee

On Appeal from the 281st District Court

Harris County, Texas

Trial Court Cause No. 2004-68579

M A J O R I T Y   O P I N I O N


In this contract-interpretation case, we determine whether the trial court properly granted summary judgment in favor of the operator of an oil and gas lease based on language in two joint operating agreements pertaining to the parties= notification of intent to participate in proposed drilling operations.  A non-operator working-interest owner brought breach-of-contract claims against the operator under these two agreements, seeking specific performance as well as damages.  The trial court granted summary judgment in favor of the operator.  We must determine whether, under the agreements, a party who has received notice of a proposed drilling operation may change its election and decide to participate in the operation within thirty days of receiving notice of the proposed operation, after that party first responded by giving notice of its election not to participate. As a matter of apparent national first impression, we conclude that, under the unambiguous language of the agreements, such a party may not change its election after it gives notice of its election to the proposing party.  Therefore, we affirm the trial court=s judgment. 

I.  Factual and Procedural Background

At the times relevant to this appeal, appellee Smith Production Inc. (ASmith@) was an operator under two joint operating agreements (AJOAs@)[1] governing exploration and production on an oil and gas lease known as the Bloomberg Lease (the ALease@).  The following parties to the JOAs were non-operating working-interest owners:  Chevron U.S.A. Inc. (AChevron@), Moran Resources Company, CNR Production, LLC, and Frost National Bank as trustee for Franke Interests, Inc. (collectively ANon-Operating Interest Owners@).

In May 2004, Chevron contracted to sell certain oil and gas properties to appellant XTO Energy Inc. (AXTO@), including Chevron=s working interest in the Lease.  A Chevron vice-president, who was in charge of the assets being sold, directed Chevron employees to operate under Athe guidelines of business as usual@ with respect to any properties involved in the transfer.  As part of her directive, the vice-president advised employees by email as follows:


The Asset Sale Agreement does not require that we need to obtain XTO=s consent for AFE=s [authorization for expenditures], purchases[,] or new drills; however, we should consult with XTO as a courtesy on any significant (over $100,000) matters considering that the effective date of the transaction is January 1, 2004 and all expenses will be deducted from the purchase price.  We should not go non-consent on any AFE=s without prior consultation with XTO.

Under the JOAs, in May and June of 2004, Smith gave written notices to the Non-Operating Interest Owners of its proposal to drill four more wells on the Lease.  Under the JOAs, the Non-Operating Interest Owners had thirty days after receipt of the notices within which to notify Smith whether they would elect to participate in the cost of the proposed operations.  After analyzing geological data and other information, Chevron decided that it did not wish to participate in the costs of the four proposed wells.  Without consulting with XTO and within the thirty-day period for responding, Chevron notified Smith that it elected not to participate in the cost of the four proposed wells. 

When Chevron notified Smith of its elections on June 17, 2004, all the other Non-Operating Interest Owners already had notified Smith of their elections to participate in the cost of the four wells.  Shortly after receiving Chevron=s notification, Smith advised the other Non-Operating Interest Owners of the total interest of the parties approving the operations.  By June 22, 2004, the other Non-Operating Interest Owners all advised Smith that they agreed to carry their proportionate share of Chevron=s interests.  On June 24, 2004, still within thirty days of Chevron=s receipt of Smith=s notices proposing the four wells, Chevron sent Smith a letter containing four signed AFEs.  In this letter, Chevron stated that it elected to participate in the cost of the four proposed wells and that it was revoking its prior notifications to the contrary, explaining that the June 17, 2004 notices had been sent in error.


          In a letter Smith responded by asserting that Chevron could not revoke its prior notifications and that Smith still considered Chevron=s June 17, 2004 elections to be effective.  Because of this position, Smith treated Chevron as a ANon-Consenting Party@ rather than a AConsenting Party@ under the JOAs.  Treating Chevron as a Non-Consenting Party would mean that, under a provision of the JOAs, upon commencement of operations for the drilling of the four wells in accordance with the JOAs, Chevron would be deemed to have relinquished to the other parties, and the other parties would own and be entitled to receive, in proportion to their respective interests, all of Chevron=s interest in the well and share of production therefrom until the proceeds of the sale of such share, calculated at the well, or market value thereof if such share is not sold, after various deductions,  equals the total of the following:  400 percent of the Chevron=

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