Justia Wyoming Supreme Court Opinion SummariesArticles Posted in Energy, Oil & Gas Law
Basic Energy Servs., LP v. Petroleum Res. Mgmt., Corp.
PRM Partners was a leaseholder of lands which covered an oil well. PRM Partners designated Petroleum Resource Managements, Corp. (PRM) as the operator of the well. PRM contracted with Hot Oil Services, Inc. to perform the day-to-day operations of the well. In 2009, Hot Oil requested that Basic Energy Services, LP perform workover operations on the well. While Basic Energy was performing the workover operations, a fire erupted, which damaged various pieces of equipment, including Basic Energy’s workover rig. Basic Energy sued PRM Partners and PRM to recover the damage to its equipment. The district court granted summary judgment for PRM Partners and PRM, concluding that Hot Oil was an independent contractor and that neither PRM nor PRM Partners could be held liable for the acts of an independent contractor. The Supreme Court (1) reversed and remanded on the issue of whether PRM breached the contract and reversed and remanded on the claim that PRM acted negligently in hiring Hot Oil, holding that the district court erred in entering summary judgment on these issues, as PRM failed to carry the initial burden of a summary judgment movant; and (2) ordered that PRM Partners be dismissed from the appeal. View "Basic Energy Servs., LP v. Petroleum Res. Mgmt., Corp." on Justia Law
Windsor Energy Group, LLC v. Noble Energy, Inc.
At issue in this case was a joint operating agreement (JOA) for Wyoming oil and gas interests entered into in 2000 by the predecessors in interest to Windsor Energy Group, LLC and Windsor Beaver Creek, LLC (together, Windsor) and Noble Energy, Inc. (Noble). In 2004, Noble’s predecessor assigned its interest to another party. In 2010, Windsor filed suit against Noble’s predecessor, claiming it was obligated for costs under the JOA. The district court ruled (1) an assignor of an interest who was not formally released was still obligated under the JOA, but (2) Windsor’s claim against Noble for breach of the JOA was barred by laches. The Supreme Court affirmed the district court’s judgment without addressing the contract issue, holding that the district court (1) did not err in ruling that the equitable doctrine of laches was an available defense to Windsor’s claim for breach of the JOA even though the statute of limitations had not expired; and (2) did not abuse its discretion by finding the elements of laches were satisfied in this case. View "Windsor Energy Group, LLC v. Noble Energy, Inc." on Justia Law
Merit Energy Co. v. Dep’t of Revenue
This case concerned Merit Energy Company's 2006 natural gas severance and ad valorem tax liability for wells located in several counties. Merit was a take-in-kind interest owner, which is a party who elects to take a portion of the mineral produced rather than receive monetary remuneration for its share of the production. The State Board of Equalization (SBOE) determined that Merit failed to timely appeal several final Wyoming Department of Revenue (DOR) decisions regarding the amount of taxable gas it had received and dismissed Merit's appeal. The district court affirmed. The Supreme Court affirmed, holding (1) the district court did not err in affirming the SBOE's dismissal as untimely; and (2) even if the Court permitted Merit to appeal the notice of valuation change sent by the DOR, the doctrine of collateral estoppel precluded Merit from doing so. View "Merit Energy Co. v. Dep't of Revenue" on Justia Law
Exxon Mobil Corp. v. Wyo. Oil & Gas Conservation Comm’n
The Wyoming Oil and Gas Conservation Commission approved Cimarex Energy Company's plan to reinject waste carbon dioxide and hydrogen sulfide into a producing natural gas formation in southwest Wyoming over the objection of Exxon Mobil Corporation. Exxon appealed. The district court affirmed the Commission's decision. The Supreme Court affirmed in part and reversed and remanded in part, holding (1) the Commission properly denied Exxon's petition for a rehearing; but (2) the Commission failed to provide sufficient findings of fact as to whether Cimarex's plan to reinject carbon dioxide and hydrogen sulfide would result in waste of natural gas and improperly interfere with Exxon's correlative rights. Remanded to the Commission to make appropriate findings of both basic and ultimate facts. View "Exxon Mobil Corp. v. Wyo. Oil & Gas Conservation Comm'n" on Justia Law
Bowers Oil & Gas, Inc. v. DCP Douglas, LLC
Bowers Oil and Gas, Inc. (BOG) entered into a Gas Purchase Contract with Kinder Morgan Operating, L.P. (Kinder Morgan), pursuant to which Kinder Morgan agreed to purchase coal bed methane gas from certain of BOG's wells. Kinder Morgan transferred its interest in the Contract, and Kinder Morgan's successor eventually terminated the Contract pursuant to a provision that allowed either party to terminate if in the terminating party's sole opinion, the sale or purchase of the gas became unprofitable or uneconomical. BOG thereafter filed suit asserting claims for breach of contract and breach of the covenant of good faith and fair dealing. Following a bench trial, the district court found no contract breach or covenant breach and ruled in favor of Kinder Morgan and its successor. Upon review, the Supreme Court affirmed. The Court found no breach of contract in the successor's removal of the pipelines connecting BOG to the gas gathering system and that the Gas Purchase Contract was properly terminated for economic cause. Furthermore, the Court found no clear error in the district court's rejection of BOG's claim for breach of the implied covenant and fair dealing. View "Bowers Oil & Gas, Inc. v. DCP Douglas, LLC" on Justia Law
Sutherland v. Meridian Granite Co.
John and Minerva Sutherland entered into a mining lease granting Meridian Granite Company the right to conduct mining operations on the Sutherlands' property. A dispute developed between the Sutherlands and Meridian regarding the Sutherlands' obligation to pay taxes relating to the mineral production. The dispute led to litigation. The district court granted Meridian's motion for summary judgment, ruling that the Sutherlands were obligated to pay the disputed taxes. The Supreme Court affirmed, holding that the district court did not err in allowing Meridian to deduct ad valorem and severance taxes from payments to the Sutherlands when such tax payments were not required by the State, as the Sutherlands and Meridian agreed in the mining lease that the Sutherlands would pay the taxes. View "Sutherland v. Meridian Granite Co." on Justia Law
Whitney Holding Corp. v. Terry
Appellant, Whitney Holding Corporation, challenged a decision of the district court quieting title in a certain mineral estate in favor of Appellees, Clarence and Peggy Terry. The Supreme Court affirmed, holding (1) the district court did not err in concluding that the parties intended, and the limited warranty deed conveying the property from Whitney to the Terrys reflected, that Whitney did not reserve a mineral interest in the property; (2) the district court properly determined that the deed was ambiguous and did not err in considering extrinsic evidence to interpret the deed; and (3) the Terrys' quiet title action was not barred by the statute of limitations. View "Whitney Holding Corp. v. Terry" on Justia Law
Exxon Mobil Corp. v. Wyo. Dep’t of Revenue
This case arose from a decision rendered by the State Board of Equalization (Board) concerning the valuation point for tax purposes of the natural gas production from the LaBarge Field. The Supreme Court remanded the issue to the Board of whether the meters located at the LaBarge Field well sites were "custody transfer meters" as defined by Wyo. Stat. Ann. 39-14-203(b)(iv) or volume meters for Exxon's share of gas production. The Board held (1) the meters were not custody transfer meters for Exxon's share of gas production, and (2) the same meters were custody transfer meters for the gas produced by two other working interest owners, petroleum companies, who were not parties to the action. The Supreme Court (1) affirmed the Board's determination that the meters were not custody transfer meters for Exxon's gas where the Board's determination harmonized with precedent established in Amoco Prod. Co. v. Dep't of Revenue; but (2) reversed the Board's determination that the meters were custody transfer meters for the petroleum companies' gas because the Board did not have the authority to determine the valuation point for "non-party" persons or entities that do not appeal their tax assessments. View "Exxon Mobil Corp. v. Wyo. Dep't of Revenue" on Justia Law
Grynberg v. L&R Exploration Venture
Celeste Grynberg and her husband were co-owners of Grynberg Petroleum. Celeste filed a complaint for declaratory relief, breach of contract, unjust enrichment, and conversion against L&R Exploration Venture and numerous individuals and entities having an interest in the venture (collectively L&R), claiming that L&R owed her compensation for services Grynberg Petroleum provided to L&R and that she was entitled to payment of those amounts. The district court granted summary judgment for L&R and dismissed the complaint on the basis of res judicata, finding that Celeste was in privity with parties involved in prior litigation in Colorado and New York and her complaint involved the same subject matter and issues resolved in those proceedings. The Supreme Court affirmed, holding that Celeste was in privity with her husband, who was a party in the New York proceedings, as the assignee of his interest in L&R and with Grynberg Petroleum as the co-owner of the company and was bound by the prior rulings. View "Grynberg v. L&R Exploration Venture" on Justia Law