Webb v. Exxon Mobil, No. 15-2879 (8th Cir. 2017)
Annotate this CasePlaintiffs filed a class action against the Pegasus Pipeline's current owners and operators, Exxon, alleging that the company's operation of the pipeline was unreasonable and unsafe. The Eighth Circuit agreed with the district court's decision to decertify the class based on a lack of commonality of issues. In this case, the contract claims would require examination of how Exxon's operation of the pipeline affects plaintiffs, which varies depending on where individual class members' property was located, as well as many other factors. The Eighth Circuit also concluded that the evidence here was insufficient to raise a genuine issue of material fact as to whether there was unreasonable interference. The court explained that the question of unreasonable use of an easement was generally one of fact, dependent on the nature of the easement, the terms of the grant, and other relevant circumstances. Finally, the district court did not clearly abuse its discretion by denying plaintiffs' motion to alter or amend the judgment where the additional evidence at issue would not have produced a different result. Accordingly, the Eighth Circuit affirmed the judgment.
Court Description: Riley, Author, with Wollman and Benton, Circuit Judges] Civil case - Contracts. In action alleging Exxon had materially breached the terms of easement contracts by failing to properly inspect and maintain a pipeline, the district court did not err in decertifying the class on the ground that the pipeline is composed of individual segments and Exxon's actions or inactions with respect to one individual's land would not necessarily implicate the interests of any other landowner; while the question of unreasonable use of an easement is generally one of fact, dependent on the nature of the easement, the grant and other circumstances, the evidence here was insufficient to raise a genuine issue of material fact as to whether Exon had unreasonably interfered with plaintiff's property, and the district court did not err in granting Exxon summary judgment on plaintiffs' breach of easement contract claims; the district court did not err in denying plaintiffs' motion to alter or amend the judgment based on a claim that Exxon delayed submitting certain discovery documents.
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