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Briggs v. Southwestern Energy Production Company, 657 Pa. 38, 224 A.3d 334

Facts

The plaintiffs, Paula, Joshua, and Sarah Briggs, own approximately eleven acres in Harford Township, adjacent to land leased by Southwestern Energy Production Company for natural gas extraction. The plaintiffs alleged that Southwestern extracted natural gas from beneath their property without permission, constituting trespass and conversion. They did not lease their land for gas production and claimed that Southwestern's actions were unlawful and disregarded their property rights.

The plaintiffs, Paula, Joshua, and Sarah Briggs, own approximately eleven acres in Harford Township, adjacent to land leased by Southwestern Energy Production Company for natural gas extraction. The plaintiffs alleged that Southwestern extracted natural gas from beneath their property without permission, constituting trespass and conversion.

Issue

Does the rule of capture apply to oil and gas produced from wells that were completed using hydraulic fracturing and preclude trespass liability for allegedly draining oil or gas from under nearby property?

Does the rule of capture apply to oil and gas produced from wells that were completed using hydraulic fracturing and preclude trespass liability for allegedly draining oil or gas from under nearby property, where the well is drilled solely on and beneath the driller's own property and the hydraulic fracturing fluids are injected solely on or beneath the driller's own property?

Rule

The rule of capture permits an owner to extract oil and gas from a common reservoir without liability for drainage from neighboring properties, provided there is no physical trespass.

The rule of capture permits an owner to extract oil and gas from a common reservoir without liability for drainage from neighboring properties, provided there is no physical trespass.

Analysis

The court analyzed whether the rule of capture applies in cases involving hydraulic fracturing, which uses artificial means to extract gas from shale formations. It noted that while the rule traditionally allows for drainage without liability, the use of hydraulic fracturing raises questions about whether such extraction constitutes a physical intrusion that could lead to trespass claims. The court emphasized that the plaintiffs must demonstrate more than just drainage to establish a trespass.

The court analyzed whether the rule of capture applies in cases involving hydraulic fracturing, which uses artificial means to extract gas from shale formations. It noted that while the rule traditionally allows for drainage without liability, the use of hydraulic fracturing raises questions about whether such extraction constitutes a physical intrusion that could lead to trespass claims.

Conclusion

The Supreme Court concluded that the rule of capture may apply in hydraulic fracturing scenarios, but a plaintiff must allege more than mere drainage to establish a trespass claim. The court vacated the Superior Court's order and remanded the case for further proceedings.

The Supreme Court concluded that the rule of capture may apply in hydraulic fracturing scenarios, but a plaintiff must allege more than mere drainage to establish a trespass claim.

Who won?

The energy company, Southwestern Energy Production Company, prevailed as the Supreme Court upheld the application of the rule of capture in hydraulic fracturing cases.

The energy company, Southwestern Energy Production Company, prevailed as the Supreme Court upheld the application of the rule of capture in hydraulic fracturing cases.

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