Basic Energy Servs., LP v. Petroleum Res. Mgmt., Corp.Annotate this Case
PRM Partners was a leaseholder of lands which covered an oil well. PRM Partners designated Petroleum Resource Managements, Corp. (PRM) as the operator of the well. PRM contracted with Hot Oil Services, Inc. to perform the day-to-day operations of the well. In 2009, Hot Oil requested that Basic Energy Services, LP perform workover operations on the well. While Basic Energy was performing the workover operations, a fire erupted, which damaged various pieces of equipment, including Basic Energy’s workover rig. Basic Energy sued PRM Partners and PRM to recover the damage to its equipment. The district court granted summary judgment for PRM Partners and PRM, concluding that Hot Oil was an independent contractor and that neither PRM nor PRM Partners could be held liable for the acts of an independent contractor. The Supreme Court (1) reversed and remanded on the issue of whether PRM breached the contract and reversed and remanded on the claim that PRM acted negligently in hiring Hot Oil, holding that the district court erred in entering summary judgment on these issues, as PRM failed to carry the initial burden of a summary judgment movant; and (2) ordered that PRM Partners be dismissed from the appeal.