Longview Energy Co. v. Huff Energy Fund LP (Corrected)Annotate this Case
The Supreme Court affirmed the decision of the court of appeals reversing the trial court’s judgment awarding a constructive trust to Longview Energy Company on certain mineral leases and related property and requiring the disgorgement of money derived from past lease production revenues.
Longview sued two of its directors and entities associated with them after discovering that one of the entities had purchased mineral leases in an area where Longview had been investigating the possibility of buying leases. The jury found (1) the directors breached their fiduciary duties to Longview by usurping a corporate opportunity and by competing with the corporation without disclosing the competition, and (2) the entity as issue acquired leases as a result of the breaches. The court of appeals reversed. The Supreme Court affirmed, holding (1) there was no evidence tracing the entity’s acquisition of any specific leases to any assumed breaches, and therefore, the trial court erred by imposing the constructive trust on and requiring the transfer of leases and properties to Longview; and (2) there was no evidence to support the trial court’s damages award.