SUMMER NIGHT OIL CO., LLC v. Munoz
2011 MT 202
| Mont. | 2011Background
- Settlement agreement from July 25, 2007 resolved the operation of two Daniels County wells, Anderson 27-1 and Anderson 27-2, with integrated best efforts language.
- Paragraph 1 requires Summer Night to pay: (a) one-half of the EPA fine due from Miocene and (b) $75,000 within six months, tied to Miocene’s investment in the wells.
- Summer Night failed to make both Paragraph 1 payments, arguing obligations were conditioned on Summer Night’s sale of the wells and Miocene’s delivery of clearance title documents.
- Miocene placed liens against Anderson 27-1 and 27-2 before and after the settlement, and later consolidated liens totaling $258,984; Summer Night contends these liens impeded sale.
- The District Court held the payments were due within a reasonable time independent of sale or title clearance, ordered Summer Night to escrow payment and Miocene to deliver title documents, and denied attorney fees.
- Summer Night appealed the district court’s interpretation and its denial of a Rule 59(g) motion to alter or amend the judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court properly denied enforcement of the Settlement Agreement per Summer Night’s terms | Summer Night argues Paragraph 1's timing was conditioned on title clearance | Miocene argues payments were not preconditioned by title clearance | Yes; court enforced plain terms, no preconditions to payment |
| Whether the district court properly denied Summer Night’s Rule 59(g) motion | Summer Night claims error in escrow/order amendments and seeks new evidence | Miocene contends no manifest error or new evidence warranting relief | Yes; court did not abuse discretion |
Key Cases Cited
- Dambrowski v. Champion Intl. Corp., 2003 MT 233 (MT 2003) (contract interpretation and reasonable time for performance under settlement)
- Byrum v. Andren, 2007 MT 107 (MT 2007) (sufficiency of evidence to support district court findings; substantial credible evidence)
- Corp. Air v. Edwards Jet Ctr., Mont., Inc., 2008 MT 283 (MT 2008) (plain meaning of unambiguous contracts; contract interpretation)
- Lee v. USAA Cas. Ins. Co., 2001 MT 59 (MT 2001) ( standards for Rule 59(g) motions to alter or amend)
- Hi-Tech Motors, Inc. v. Bombardier Motor Corp. of Am., 2005 MT 187 (MT 2005) (limitations on relitigating matters via Rule 59(g))