SWN Production Co., LLC. v. Conley (Signed Opinion)Annotate this Case
The Supreme Court reversed the order of the circuit court denying SWN Production Company's motion to intervene in an action seeking to quiet title to a parcel of property brought by Corey Conley, holding that the circuit court abused its discretion and erred as a matter of law.
The underlying action involved competing claims and interests in the mineral rights to Conley's property. SWN asserted that it had interests in oil and gas properties that would be affected by interpretation of the relevant deed. After Conley filed his complaint, SWN filed a motion to intervene, which the circuit court denied. Thereafter, SWN entered into an oil and gas lease with Conley. SWN then filed a second motion to intervene, which the circuit court denied. The Supreme Court reversed and remanded the case for further proceedings, holding that the circuit court (1) abused its discretion in determining that the SWN motion to intervene was untimely; and (2) erred as a matter of law in finding that SWN had no property interest relating to the subject of the complaint, that disposition of the civil action would not impair or impede SWN's ability to protect its interests, and that SWN's interests were adequately protected by Conley.