Beardslee v. Inflection Energy, LLC, No. 12-4897 (2d Cir. 2014)Annotate this Case
This dispute concerns oil and gas leases granting the Energy Companies specified rights to extract oil and gas underlying the Landowners' real property. The Energy Companies failed to produce oil and gas from the properties within the leases' primary terms and the Landowners subsequently filed suit seeking a declaration that the leases had expired. On appeal, the Energy Companies challenged the district court's grant of summary judgment to Landowners, and denial of summary judgment to the Energy Companies. The court concluded that this case turns on significant and novel issues of New York law concerning the interpretation of oil and gas leases and the court certified two questions of New York law to the New York Court of Appeals: (1) Under New York law, and in the context of an oil and gas lease, did the State's Moratorium amount to a force majeure event? and (2) If so, does the force majeure clause modify the habendum clause and extend the primary terms of the leases?
The court issued a subsequent related opinion or order on August 19, 2015.