AI Generated Opinion Summaries

Decision Information

Decision Content

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

  • Chica Energy, LLC, filed a claim against COG Operating, LLC, concerning an agreement and subsequent assignment of interests in a well from Biscuit Hills Disposal, LLC, to COG Operating. Chica Energy contended that the assignment was not lawful and effective, thereby affecting its interests. Additionally, Chica Energy argued for damages under a theory of quantum meruit, claiming unjust enrichment for water disposed of by COG Operating in the well, for which Chica Energy was not compensated according to the terms of the contract.

Procedural History

  • [Not applicable or not found]

Parties' Submissions

  • Plaintiff-Appellee (Chica Energy, LLC): Argued that there was not substantial evidence to support the district court's conclusion that the agreement and assignment between Biscuit Hills Disposal, LLC, and COG Operating, LLC, were lawful and effective. Additionally, contended that the district court erred in refusing to award damages for unjust enrichment under a theory of quantum meruit.
  • Defendant-Appellant (COG Operating, LLC): [Not applicable or not found]

Legal Issues

  • Whether there was substantial evidence to support the district court's decision that the agreement and assignment of interests in the well from Biscuit Hills Disposal, LLC, to COG Operating, LLC, were lawful and effective.
  • Whether the district court erred in refusing to award damages for unjust enrichment under a theory of quantum meruit.

Disposition

  • The Court of Appeals affirmed the district court's judgment dismissing Chica Energy's claim against COG Operating.

Reasons

  • Per LINDA M. VANZI, Judge (CYNTHIA A. FRY, Judge, and TIMOTHY L. GARCIA, Judge, concurring):
    The Court of Appeals was not persuaded by Chica Energy's arguments regarding the sufficiency of the evidence to support the district court's decision. The Court noted that the assignment and bill of sale constituted substantial evidence of a lawful and effective assignment of Biscuit Hill Disposal’s interests in the well to COG Operating. The Court also highlighted that Chica Energy's challenge to the legal conclusion of the assignment's effectiveness lacked relevant authority to demonstrate legal error. Regarding Chica Energy's claims of error for not making findings contrary to those made by the district court, the Court explained that its review does not permit evaluation of evidence to support findings not made by the district court. The Court emphasized that the question on appeal is whether substantial evidence supports the result reached, not whether it could support an opposite result.
    On the issue of quantum meruit, the Court found no error in the district court's refusal to award damages for unjust enrichment, stating that a contract is generally enforced as written. The Court rejected Chica Energy's assertion of real hardship and oppression due to not being paid for water disposal, clarifying that the contract only entitled Chica Energy to payments from revenues received by COG Operating for charging third parties for water disposal in the well. The Court concluded that Chica Energy's lack of entitlement to payments not stipulated in the contract does not warrant equitable relief from the contract's clear terms.
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