Justia Energy, Oil & Gas Law Opinion Summaries

Watson’s father, Hickle, worked for the Department of Energy, 1954 to 1962. Hickle died of Hodgkin’s disease in 1964. Congress enacted the Energy Employees Occupational Illness Compensation Program Act in 2000 to compensate for illnesses caused by exposure to radiation and other toxic substances while working for the Department of Energy. Covered employees or eligible survivors may receive compensation in a lump sum payment; under specific circumstances, a covered employee’s child is also eligible, 42 U.S.C. 7385s-3(d)(2). When her father died, Watson was 19 years old, not a full-time student; she lived with her parents, worked as a waitress, relied on her parents for support, and was listed as a dependent on their income tax returns. She sought survivor benefits in 2002 and received a lump-sum payment of $150,000. She later claimed further compensation as a “covered child,” under a different section of the Act, arguing that she was “incapable of self-support” at the time of Hickle’s death. The Department of Labor denied her claim. Before the district court, Watson challenged the interpretation of “incapable of self-support,” claiming that the Department impermissibly required a showing of physical or mental incapability. The district court denied her motion for summary judgment. The Sixth Circuit affirmed. View "Watson v. Solis" on Justia Law

Banks worked as a coal miner for 17 years and smoked about one pack of cigarettes per day for 38 years. His employment ended in 1991. After two unsuccessful attempts, in 2003, Banks filed a claim for benefits under the Black Lung Benefits Act, which provides benefits to coal miners who become disabled due to pneumoconiosis, 30 U.S.C. 901. An ALJ found that Banks had shown a change in his condition and that he suffered from legal pneumoconiosis which substantially contributed to his total disability. Banks was awarded benefits and the Benefits Review Board affirmed. The Sixth Circuit affirmed, adopting the regulatory interpretation urged by the Director of the Office of Workers’ Compensation Programs. The ALJ relied on reasoned medical opinions. View "Cumberland River Coal Co. v. Banks" on Justia Law

The Stockmans entered into an extension of their mineral lease with Chesapeake Louisiana, L.P. and received a $240,000 bonus. In May 2008, the Stockmans entered into a mineral lease with Petrohawk Properties, L.P. for a $1.45 million bonus. Petrohawk then dishonored the draft and executed a second mineral lease with the Stockmans, paying them a $1.7 million bonus. Chesapeake sued the Stockmans for breach of contract, and the parties settled at trial. The Stockmans then sued Petrohawk for fraud in obtaining the first mineral lease, and Chespeake sued Petrohawk for intentional interference with its contract with the Stockmans. The district court (1) found that Petrohawk procured the first mineral lease by fraud and rescinded the lease, (2) dismissed Chesapeake's tort claim, and (3) dismissed Petrohawk's claim for a return of its bonus money. The Fifth Circuit Court of Appeals affirmed, holding (1) Petrohawk obtained the first lease by fraud, and the district court did not err in rescinding the lease, awarding attorney's fees to the Stockmans; (2) the district court did not err in dismissing Petrohawk's counterclaim for the return of the lease bonus; and (3) the district court correctly dismissed Chespeake's intentional interference with a contract claim. View "Petrohawk Props., L.P. v. Chesapeake Louisiana, L.P." on Justia Law

In August of 2009, Samson Resources Company owned oil and gas leases covering 87.78 mineral acres in Roger Mills County, Oklahoma, including the Schaefer Lease. The Schaefer Lease covered 70 net acres in the Southwest Quarter of Section 28 and had a three-year primary term that ended on November 22, 2007. If drilling operations were commenced by the end of the primary term, the lease would continue so long as such operations continued. On August 2, 2007, Newfield sent a letter to Samson, proposing to drill a well in Section 28. The estimated cost of the well was over $8.5 million dollars. On August 9, 2007, Newfield filed an application with the Commission, seeking to force pool the interests of Samson and other owners in Section 28. Newfield sent an e-mail dated April 14, 2008, to Samson that informed Samson that Newfield had commenced operations prior to the expiration of the Schaefer Lease. Newfield's e-mail stated that Samson had underpaid well costs and that an election to participate with 87.78 acres would require prepayment of $1,411,982.45. Samson responded by e-mail on the same date, informing Newfield its intent was only to elect its 17.78 acres. On April 28, 2008, Samson filed an Application seeking to have its election to participate in the well limited to 17.78 acres rather than 87.78 acres. After an administrative hearing, the Administrative Law Judge determined that Samson's timely election to participate only covered 17.78 acres of its interest and that Samson accepted the cash bonus as to its remaining 70 acres. The Oil and Gas Appellate Referee reversed the ALJ's determination, finding that the ALJ improperly relied on actions which occurred prior to the issuance of the pooling order. The Commission issued Order No. 567706, which adopted the Referee's report, reversed the ALJ, and declared that Samson had elected to participate to the full extent of its 87.78 acre interest in the unit. The Commission found Samson made a "unilateral mistake" when it elected to participate to the full extent of its interest. Samson appealed the Commission's order to the Court of Civil Appeals, which affirmed. Before COCA issued its opinion affirming the Commission, Samson filed an action in the district court alleging actual fraud, deceit, intentional and negligent misrepresentation, constructive fraud, and breach of duty as operator. Samson also alleged Newfield's actions amounted to extrinsic fraud on the Commission, rendering Pooling Order No. 550310 invalid as to Samson's working interest attributable to the 70-acre Schaefer Lease. The trial court granted Newfield's motion to dismiss for lack of subject matter jurisdiction, finding the petition to be an impermissible collateral attack on a valid Commission order. The Court of Civil Appeals affirmed. After its review, the Supreme Court found that Samson's actions for damages sounding in tort were beyond the Commission's jurisdiction, and the district court in this case was the proper tribunal for Samson to bring its claims. The trial court's order granting Newfield's Motion to Dismiss was reversed, and the case was remanded for further proceedings. View "Samson Resources Co. v. Newfield Exploration Mid-Continent, Inc." on Justia Law

RSM Production Corporation brought a complaint against a law firm and two of its partners ("Freshfields"), alleging that Freshfields, through its representation of the nation of Grenada in international arbitration, conspired to violate the Racketeer Influenced and Corrupt Organizations Act (RICO) in an effort to prevent RSM from obtaining an exclusive license for offshore oil and gas exploration and development in Grenada. The district court ruled that RSM's lawsuit was barred under the doctrine of res judicata because of its prior lawsuit in the Southern District of New York regarding the same licensing effort. On appeal, RSM contended that Freshfields was not in privity with the New York defendants and that RSM was not required to add Freshfields as a party to that litigation on pain of res judicata. The D.C. Circuit Court of Appeals affirmed on the alternative ground that RSM's complaint failed to state a claim of RICO conspiracy against Freshfields. View "RSM Prod. Corp. v. Freshfields Bruckhaus Deringer U.S. LLP" on Justia Law

This appeal arose from a negligence action brought by Plaintiff-Appellant Isabel Enriquez against Defendant-Respondent Idaho Power Company (Idaho Power). Plaintiff received severe electrical burns when he encountered an aluminum sprinkler pipe that had become energized by a high-voltage power line. He claimed that after the power line broke and electrified the pipe, Idaho Power's safety equipment did not shut off the current to the downed line, allowing him to be shocked when he approached the pipe to move it. The case went to trial, and Plaintiff argued that Idaho Power was negligent under the doctrine of res ipsa loquitur. At the close of Plaintiff's case in chief, Idaho Power moved for a directed verdict. The district court determined that res ipsa loquitur did not apply to the facts of this case and granted the motion. On appeal, Plaintiff argued that the district court erred in holding that res ipsa loquitur did not apply and the directed verdict was therefore improper. Upon review of the trial court record, the Supreme Court concluded the trial court did not abuse its discretion when it granted a directed verdict in favor of the power company. Accordingly, the Court affirmed the trial court's decision. View "Enriquez v. Idaho Power Co." on Justia Law

Respondent, widow of an employee of Pacific Operators Offshore, sought benefits under the Longshore and Harbor Workers' Compensation Act (LHWCA), 33 U.S.C. 901 et seq., pursuant to the Outer Continental Shelf Lands Act (OCSLA), 43 U.S.C. 1333(b), which extended LHWCA coverage to injuries "occurring as the result of operations conducted on the [OCS]" for the purpose of extracting natural resources from the shelf. The ALJ dismissed her claim, reasoning that section 1333(b) did not cover the employee's fatal injury because his accident occurred on land, not on the OCS. The Labor Department's Benefits Review Board affirmed, but the Ninth Circuit reversed. The Court concluded that the Ninth Circuit's "substantial-nexus" test was more faithful to the text of section 1333(b). The Court understood the Ninth Circuit's test to require the injured employee to establish a significant causal link between the injury that he suffered and his employer's on-OCS operations conducted for the purpose of extracting natural resources from the OCS. View "Pacific Operators Offshore, LLP v. Valladolid" on Justia Law

Defendant Baker Hughes Inteq, Inc. appealed the district court's order that denied its motion to compel arbitration. Plaintiff EEC, Inc. and Baker contracted for Baker to provide drilling equipment for use in EEC's horizontal oil and natural gas well in Oklahoma. The equipment was lost in the well. EEC filed suit in Oklahoma state court alleging that Baker’s negligence damaged its well. Baker removed the case to federal court, invoked diversity jurisdiction, and filed counterclaims for the value of its equipment. Baker also sought to compel arbitration. Baker prepared and EEC signed numerous documents containing arbitration clauses which were ultimately ruled as unenforceable by the district court. The court also denied Baker’s motion to reconsider. Further, the court enjoined Baker from proceeding with arbitration, and stayed further district court proceedings pending appeal of its orders. Upon review of the arbitration clauses at issue in this case, the Tenth Circuit found disagreed that because there were differences in the multiple clauses they were rendered unenforceable. The Court reversed the district court's judgment denying Baker's motion to compel arbitration and remanded the case with directions to order the parties to pursue arbitration. View "EEC, Inc. v. Baker Hughes Oilfield" on Justia Law

The issue on appeal to the Supreme Court in this case pertained to the standards a trial court applies when it decides whether to certify a class pursuant to C.R.C.P. 23. The Supreme Court reversed the court of appeals' rulings: that the trial court must apply a "preponderance of the evidence" standard to C.R.C.P. 23's requirements, that the trial court must resolve factual or legal disputes dispositive of class certification regardless of any overlap with the merits, and that the trial court must resolve expert disputes regardless of any overlap with the merits. The Court also concluded that the trial court rigorously analyzed the evidence in determining that Plaintiffs in this case established an identifiable class and satisfied C.R.C.P. 23(b)(3)'s "predominance" requirement. View "Jackson v. Unocal Corp" on Justia Law

John and Betty Vlasin leased the oil and gas rights to their land to Ranch Oil Company. Ranch Oil operated on one-half of the land in the lease and Byron Hummon operated on the other half. After the primary term of the lease expired and the wells stopped producing oil, the Vlasins entered into a new lease agreement with Hummon which encompassed the entirety of their land. Thereafter, Ranch Oil took action to revive one of its dormant wells, relying on a savings provision of the lease, which stated that the lease shall not terminate if the lessee commences operations for drilling a well within sixty days from such cessation. Plaintiffs, the Vlasins and Hummon, brought suit against Ranch Oil for declaratory judgment, trespass, and conversion. The court ruled in favor of Plaintiffs but awarded only nominal damages. The Supreme Court affirmed, holding that the district court did not err in concluding (1) Ranch Oil's activities on the Vlasins land did not operate so as to extend Ranch Oil's interest in the lease, and (2) Plaintiffs failed to prove they were entitled to damages under trespass and conversion claims, and the Vlasins were entitled only to nominal damages. View "Bedore v. Ranch Oil Co." on Justia Law