Thursday, November 14, 2013

Court denies summary judgment in tortious interference action brought by a field services employee owning leased land

On November 4, 2013, the United States District Court for the Western District of Pennsylvania adopted the report and recommendation of a magistrate judge to deny a well operator’s motion for summary judgment. Mason v. Range Resources-Appalachia, LLC, 2013 WL 5890725 (W.D. Pa. Nov. 4, 2013). The plaintiff landowner owns land that subject to a lease between previous owners and the Manufacturers Light and Heat Company, which is currently sub-leased by Range Resources (defendant well-operator). The lease provided for the use of the subsurface for the storage of gas, and the right to produce. The landowner refused to modify the lease in negotiations with the operator and encouraged other landowners to do the same. Throughout this time, the landowner was employed with an oil field services company employed by the well operator. The well operator allegedly ordered the field service company to disallow the landowner from the well operator’s sites, which resulted in a significant demotion to the landowner. The landowner refused to accept the demotion and was terminated. As a result, the landowner brought suit against the well operator for tortious interference with contractual relations. The court denied the well operator’s motion for summary judgment because demonstration of the intent of the well operator is determined by a trier of fact and not as a matter of law. The court explained that the intent of the operator was a genuine issue of material fact because the operator did not submit any evidence of its actual motive in directing the actions of the field services company. As the movant, the operator failed to demonstrate the non-existence of a genuine issue of material fact because it did not provide any justification for directing the operator’s actions.

Written by: Garrett Lent, Research Assistant
Agricultural Law Resource and Reference Center
November 11, 2013

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