Justia U.S. 5th Circuit Court of Appeals Opinion SummariesArticles Posted in Contracts
Apache Deepwater, LLC v. W & T Offshore, Inc.
After a successful plugging and abandonment operation of three offshore oil and gas wells, Apache sought payment from its non-operator partner, W&T. The jury subsequently awarded Apache $43.2 million for W&T's breach of the Joint Operating Agreement (JOA). The Fifth Circuit affirmed the district court's denial of W&T's motion for judgment as a matter of law, holding that Louisiana Civil Code Article 2003 did not bar Apache's entitlement to damages. The court affirmed the district court's denial of W&T's motion for summary judgment, holding that the jury needed to resolve the question of the parties' intent in light of the ambiguity of Section 6.2 of the JOA. Finally, the court affirmed the district court's denial of W&T's motion for entry of judgment and motion for a new trial, because W&T was not entitled to an offset. View "Apache Deepwater, LLC v. W & T Offshore, Inc." on Justia Law
Glassell Non-Operated Interests Ltd. v. Enerquest Oil & Gas, LLC
After a group of oil companies agreed to cooperatively develop oil prospects, EnerQuest acquired an interest in the specified area after the agreement took effect, but then refused to offer a share of those interests to the other parties. Other parties to the agreement filed suit against EnerQuest, alleging that it breached the contract by refusing to offer a pro-rata share of the newly acquired interests. The Fifth Circuit reversed the district court's judgment and rendered judgment for EnerQuest, holding that EnerQuest did not breach the agreement. The court held that, although the contract requires that the parties share interests acquired within the area of mutual interest (AMI), the contract excludes interests already owned by parties from the AMI. Therefore, what was excluded from the AMI at the outset may never be included without a new agreement. View "Glassell Non-Operated Interests Ltd. v. Enerquest Oil & Gas, LLC" on Justia Law
Cohen v. Allstate Insurance Co.
Plaintiff filed suit against Allstate and its agent for breach of contract after Allstate refused to pay a claim for flood damage. The Fifth Circuit affirmed the district court's judgment in favor of Allstate, holding that the district court did not err in granting summary judgment on the breach of contract claim because the claim was time-barred. The court also held that the district court did not abuse its discretion in denying petitioner's Federal Rule of Civil Procedure 59(e) motion. View "Cohen v. Allstate Insurance Co." on Justia Law
Halliburton Energy Services, Inc. v. Ironshore Specialty Insurance Co.
This appeal stemmed from a dispute over who was liable for damages from an oil rig that caught fire and exploded. Statoil operated the rig, Halliburton fracked at the rig site, and Ironshore insured Statoil. The Fifth Circuit held that the district court erred when it held that Ironshore waived its subrogation rights under the Master Services Agreement between Statoil and Halliburton. Therefore, the court reversed the district court's arbitration ruling in appeal No. 17-20678. However, the court held that the district court correctly determined that it lacked personal jurisdiction over Ironshore. Accordingly, the court affirmed the district court's personal jurisdiction ruling in appeal No. 18-20239. View "Halliburton Energy Services, Inc. v. Ironshore Specialty Insurance Co." on Justia Law
Alonso v. Westcoast Corp.
After a jury found that Westcoast was liable for breaching a contract it entered with RCS, Westcoast raised claims of error regarding the finding of a bad-faith breach, the language of the verdict form, and the award of attorney fees. In this case, the jury had awarded RCS $304,189 on the bad faith breach of contract claim, $66,450 under the state Prompt Payment Act, $130,517.60 in attorney fees, and $400 in costs. The Fifth Circuit vacated and remanded the penalty amount determined under the Louisiana Prompt Payment Act, holding that the jury awarded damages exceeding those permitted under the clear language of the Act. The court also vacated and remanded the award of attorney fees for reconsideration of the amount after the statutory penalty was reconsidered. View "Alonso v. Westcoast Corp." on Justia Law
ENI US Operating Company, Inc. v. Transocean Offshore Deepwater Drilling, Inc.
This case stemmed from a contract dispute between two oil-drilling businesses, Eni and Transocean. The district court granted judgment in favor of Transocean and rejected Eni's claims surrounding Transocean's maintenance of its equipment, found that Eni had wrongfully repudiated the contract, and awarded damages to Transocean. The Fifth Circuit vacated the damages award and held that the district court erred by simply applying the Standby Rate because Eni never issued any instructions after repudiation. In this case, the district court should have attempted to determine, in the hypothetical nonbreach world, how many days the Deepwater Pathfinder would have spent at each applicable rate. Accordingly, the court remanded with instructions to recalculate the damages using the correct methodology. The court found Eni's remaining arguments lacking in merit and affirmed as to those claims. View "ENI US Operating Company, Inc. v. Transocean Offshore Deepwater Drilling, Inc." on Justia Law
Encompass Off Solutions, Inc. v. Louisiana Health Service & Indemnity Co.
Encompass filed suit against Blue Cross for violations of the Employee Retirement Income Security Act (ERISA), breach of contract, defamation, and tortious interference with business relations. After Blue Cross largely prevailed at trial, the district court granted a new trial because of error in the jury charge. At the second trial, Encompass prevailed on all claims. The Fifth Circuit held that charging the jury with an incorrect standard of liability supported granting a new trial, and thus the district court did not abuse its discretion by granting Encompass a new trial on the breach of contract claims. The court also held that the district court did not abuse its discretion by granting a new trial on the tort claims considering the interdependence of the tort and contract issues. Finally, the court held that the application of contra non valentem was not wrong as a matter of law, and Blue Cross abused its discretion by arbitrarily denying Encompass's claims for covered services under ERISA. View "Encompass Off Solutions, Inc. v. Louisiana Health Service & Indemnity Co." on Justia Law
Mid-Continent Casualty Co. v. Petroleum Solutions, Inc.
Mid-Continent filed a declaratory judgment action seeking a declaration that it did not owe coverage for a judgment assessed against its insured, PSI. The district court ruled that the Cooperation Clause in the policy applied to PSI's third-party claim in the underlying lawsuit and that only parts of the judgment were covered. The Fifth Circuit affirmed in part and held that, regardless of whether the Cooperation Clause applied to affirmative claims, the Cooperation-Clause jury instruction was not an abuse of discretion. The court reversed the district court's conclusion that the Professional Liability Endorsement did not cover the entire judgment and held that it did. View "Mid-Continent Casualty Co. v. Petroleum Solutions, Inc." on Justia Law
Living Benefits Asset Management v. Kestrel Aircraft Co.
Debtor brought an adversary proceeding against Kestrel for breach of contract, alleging that Kestrel failed to pay for services owed that debtor provided Kestrel to help it collateralize a corporate debt offering with life settlements. The Fifth Circuit affirmed the district court's judgment upholding the bankruptcy court's holding that the contract was voidable because debtor failed to register as an investment adviser in violation of the Investment Advisers Act of 1940. The court held that debtor contracted with Kestrel to advise it about life settlements, and the life settlements contemplated in the origination agreement were investment contracts within the meaning of the Act. View "Living Benefits Asset Management v. Kestrel Aircraft Co." on Justia Law
Wease v. Ocwen Loan Servicing, LLC
In this action involving a Texas mortgage dispute, the Fifth Circuit held that there was ambiguity in the contract's escrow provisions and thus the district court erred by granting summary judgment to defendants on claims arising from that ambiguity. The court noted that, at this stage, it was premature to conclude that defendants were entitled to their foreclosure counterclaim. Therefore, the court vacated the foreclosure ruling and remanded for reconsideration. The court affirmed the district court's grant of summary judgment for defendants on the Real Estate Settlement Procedures Act claim, and the district court's judgment on the Texas Debt Collection Practices Act claim. View "Wease v. Ocwen Loan Servicing, LLC" on Justia Law