Lake Eugenie Land & Development, Inc. v. BP Exploration & Production, Inc.
744 F.3d 370
| 5th Cir. | 2014Background
- Settlement Agreement approved by district court in 2012 to process Deepwater Horizon business losses.
- BEL claims framework uses Exhibit 4B for causation with exemptions and quantitative tests.
- Exhibit 4B includes a causation framework and a footnote limiting applicability to economic class.
- Policy Statements (2012, 2013) and district court rulings directed matching revenues/expenses and addressed causation.
- Certification panel later held class certification and settlement approval compatible with Article III, Rule 23, and the Rules Enabling Act.
- District court ultimately interpreted the agreement to require no external causation proof beyond the attestation, and the injunction on BEL payments was ordered then vacated on appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does the causation framework violate Article III or Rule 23? | BP argues Exhibit 4B requires external causation proof. | Court argues causation was subordinated, not eliminated, by the agreement. | No violation; causation subordinated within the contract. |
| Is Exhibit 4B footnote controlling causation requirements? | Footnote 1 expands class to require no causation. | Footnote does not override the Exhibit 4B framework. | Footnote does not defeat the causation framework. |
| Was matching of revenues and expenses required in BEL claims? | BP favored no matching as per initial policy. | District court correctly required matching per October 2013 remand. | District court's matching requirement affirmed. |
| Should the injunction blocking BEL payments be maintained? | BP sought permanent injunction to stop payments lacking causation. | Injunction should stay until all issues resolved; may be dissolved after ruling. | Injunction dissolved on appeal; but remains until mandate issued. |
Key Cases Cited
- In re Deepwater Horizon, 739 F.3d 790 (5th Cir. 2014) (certification upheld; settlement compatible with Article III, Rule 23, and ENA)
- In re Deepwater Horizon, 732 F.3d 326 (5th Cir. 2013) (remand on causation and matching; prior panel decision)
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (standing requirements for justiciability)
- Lewis v. Casey, 518 U.S. 343 (1996) (standing and injury-in-fact principles in context)