Revolution Resources, LLC v. Annecy, LLC

Summary

The Oklahoma Supreme Court reviewed the denial of Annecy, LLC's motion for a temporary injunction against Revolution Resources, LLC's oil and gas drilling operations under the Oklahoma Surface Damages Act. The court held that Annecy failed to establish irreparable harm because diminution in the surface estate's value could be compensated through monetary damages under the Act. The court affirmed the trial court, dissolved the temporary injunction issued during the appeal, and remanded for proceedings concerning costs and attorney fees secured by the bond.

Holdings

1. The district court did not abuse its discretion in denying Annecy's motion for a temporary injunction because the record provided a rational basis for finding that Annecy had not established irreparable harm.
2. The Surface Damages Act provides a full and adequate remedy at law for diminution in the fair market value of a surface estate caused by oil and gas drilling and maintenance operations; a temporary injunction is therefore unavailable for that injury.
3. The Supreme Court could not decide whether Annecy was entitled to a municipal variance proceeding or whether its due-process rights were violated because that issue was pending in a separate declaratory-judgment action and had not been resolved by a final district-court judgment.
4. Because the district court's denial of a temporary injunction was affirmed, the temporary injunction issued by the Supreme Court pending appeal had to be dissolved, and the matter of costs and attorney fees secured by Annecy's bond was remanded to the district court.

Questions Presented

1. Whether the district court abused its discretion by denying Annecy's motion for a temporary injunction against oil and gas drilling under the Oklahoma Surface Damages Act.
2. Whether Annecy established irreparable harm by clear and convincing evidence when its alleged injury consisted of diminution in the fair market value of the surface estate.
3. Whether Annecy's due-process challenge concerning a possible Oklahoma City board-of-adjustment variance hearing was ripe for consideration in the Surface Damages Act interlocutory appeal.

Disposition

reversed_and_remanded