Moore v. Equitrans, L.P., No. 21-1134 (4th Cir. 2022)
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In 2012, the Moores sued, claiming that Equitrans breached the parties’ right-of-way agreement and trespassed on the Moores’ land by laying two pipeline segments outside of the area specified in their agreement. A jury found that Equitrans either trespassed on the Moores’ West Virginia property or violated the right-of-way agreement but made no findings as to the proper remedy. While the Moores initially sought equitable relief (ejectment), a subsequent condemnation judgment in favor of Equitrans ultimately precluded such relief. Following several appeals, the district court allowed the Moores to pursue damages for breach-of-contract and trespass but denied leave to add a claim for intentional trespass. Later, the district court barred any claim for breach-of-contract damages. After excluding much of the Moores’ evidence of trespass damages, the court sua sponte entered judgment in favor of Equitrans.
The Fourth Circuit vacated in part. The district court did not abuse its discretion in denying leave to amend, in making its motion in limine rulings, or in entering judgment in favor of Equitrans on contract damages. The court rejected a contention that the proper measure of trespass damages includes a portion of Equitrans’s profits. Because the Moores lacked sufficient notice that they needed to come forward with all evidence of trespass damages, the court vacated the portion of the judgment concerning trespass damages for procedural error and remanded.
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