Summary
This Business Court of Texas opinion addresses a defendant's plea to the jurisdiction challenging the court's subject-matter authority over a breach-of-contract dispute between two oil and gas entities. The court analyzes whether the parties' reciprocal waiver agreement constitutes a qualified transaction with consideration exceeding $10 million under Texas Government Code § 25A.004(d)(1). Applying liberal pleading standards and reviewing jurisdictional evidence, the court concludes that the plaintiff sufficiently alleged and supported the requisite jurisdictional facts. Consequently, the court denies the defendant's plea and retains jurisdiction over the action.
Topics
Practice areas
Questions Presented
- Whether the plaintiff pleaded sufficient facts to establish subject‑matter jurisdiction under Texas Government Code §25A.004(d)(1).
- Whether the defendant's plea to the jurisdiction should be denied.
Holdings
- The court held that Slant has pleaded sufficient facts to satisfy both the amount‑in‑controversy and qualified‑transaction requirements of §25A.004(d)(1).
- The court denied Octane’s plea to the jurisdiction.
Key quotations
“Subject‑matter jurisdiction is essential to a court’s power to decide a case.” (¶11)
“When a plea to the jurisdiction attacks the existence of jurisdictional facts, the court must consider the relevant evidence when necessary to resolve the jurisdictional issues raised.” (¶14)
Factual background
Slant Operating, LLC and Octane Energy Operating, LLC entered into a reciprocal waiver agreement concerning off‑lease drilling permits. The parties dispute whether the agreement constitutes a "qualified transaction" with consideration of at least $10 million, which is required for the Texas Business Court's subject‑matter jurisdiction under Tex. Gov't Code §25A.004(d)(1).
Procedural history
Slant filed an original petition in the 48th Judicial District Court, Tarrant County, then removed the case to the Texas Business Court. Octane filed a plea to the jurisdiction challenging subject‑matter jurisdiction under Tex. Gov't Code §25A.004(d)(1). The Business Court held that Slant had pleaded sufficient facts and denied the plea.
Remand instructions
The case is remanded to the 48th Judicial District Court, Tarrant County.