Devon Energy Production, LP v. Grayson Mill Operating, LLC
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In this case concerning a "race to permit" dispute between the parties in this case, both of whom held mineral interests in certain drilling and spacing units and both of whom wanted to be the "operator" of those units, the Supreme Court reversed the judgment of the district court granting Defendant's motion to dismiss for lack of subject matter jurisdiction, holding that the district court and not the Wyoming Oil and Gas Conservation Commission was the proper forum to resolve this case.
Defendant won the race to permit and obtained operator status over the lands at issue. Plaintiff filed a complaint alleging that Defendant violated Wyo. Stat. Ann. 40-27-101, which prohibits a party from trespassing on private lands to unlawfully collect resource data. The district court granted Defendant's motion to dismiss, concluding that the Commission had primary jurisdiction to resolve the dispute and that Plaintiff failed to exhaust its administrative remedies. The Supreme Court reversed, holding (1) Plaintiff sufficiently pleaded standing under section 40-27-101 and the Declaratory Judgments Act; (2) the district court abused in dismissing the complaint for failure to exhaust administrative remedies because the Commission did not have jurisdiction to consider Plaintiff's civil trespass claim; and (3) the court abused its discretion in relying on the primary jurisdiction doctrine.
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