Northern Oil and Gas, Inc. v. EOG Resources, Inc., No. 19-1326 (8th Cir. 2020)
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Northern filed a quiet-title action in federal court against EOG over a dispute regarding the parties' competing interests in mineral rights in North Dakota. Northern and EOG both lease oil and gas rights, and their lessors litigated a similar matter in state court. The district court found that Northern was in privity with its lessor, holding that the lessors' case barred Northern's claims.
The Eighth Circuit reversed the district court's grant of EOG's motion to dismiss under principles of res judicata, holding that no privity exists between Northern and its lessor because Northern acquired its lease before the lessors' case. The court applied Gerrity Bakken, LLC v. Oasis Petroleum N. Am., LLC, 915 N.W.2d 677 (N.D. 2018), and held that the privity doctrine cannot be applied if the rights to property were acquired by the person sought to be bound before the adjudication.
Court Description: [Smith, Author, with Melloy and Shepherd, Circuit Judges] Civil case - Quiet Title. Both parties lease oil and gas rights, and Northern filed this quiet-title action in federal court to resolve their competing interests in mineral rights in North Dakota; both parties' lessors had litigated a similar suit regarding competing interests in state court, and the district court found Northern was in privity with its lessor and that the lessors' case barred Northern's quiet-title claims under the doctrine res judicata; here, however, Northern acquired its lease before the lessors' case, and no privity exists between Northern and its lessor - see Gerrity Bakken, LLC v. Oasis Petroleum N. Am., LLC, 915 N.W.2d 677 (N.D. 2018); reversed and remanded for further proceedings.
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