EOG RESOURCES, INC. v. LUCKY LAND MANAGEMENT, LLC - Articles

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EOG RESOURCES, INC. v. LUCKY LAND MANAGEMENT, LLC

Posted by: Azya Thornton on Apr 14, 2025

Court: 6th Circuit Court (Published Opinions)

Attorneys 1: ARGUED: Daniel P. Corcoran, THEISEN BROCK, Marietta, Ohio, for Appellant.

Attorneys 2: ARGUED: Christopher J. Baronzzi, PORTER, WRIGHT, MORRIS & ARTHUR LLP, Columbus, Ohio, for Appellee.

Attorneys 3: ON BRIEF: Daniel P. Corcoran, THEISEN BROCK, Marietta, Ohio, for Appellant.

Attorneys 4: ON BRIEF: Christopher J. Baronzzi, Robert J. Karl, Kyle C. Gilliam, PORTER, WRIGHT, MORRIS & ARTHUR LLP, Columbus, Ohio, for Appellee.

Judge(s): United States District Court for the Southern District of Ohio at Columbus

Court Appealed: THAPAR, NALBANDIAN, and DAVIS, Circuit Judges

NALBANDIAN, Circuit Judge. Lucky Land Management owns property in Ohio. EOG Resources has drilling rights to the oil and gas under that property. The two couldn’t agree on whether EOG’s rights to drill included the right to drill from Lucky Land’s surface out to adjacent properties as well. So EOG sued. EOG then asked the district court to grant a preliminary injunction letting the company access the land to cut down trees and start constructing drills. The district court did so, finding that EOG would probably succeed on the merits. We disagree. Lucky Land has the better reading of oil-and-gas law; generally speaking, your leased drilling rights don’t let you use the land’s surface to drill into neighboring lands, too. What’s more, EOG wouldn’t have suffered any irreparable injury if it had to wait while the litigation progressed. And preliminary injunctions aren’t shortcuts to the merits—by preventing irreparable injuries, they simply preserve the court’s ability to issue meaningful final relief at the end of the case. So they aren’t appropriate when there’s no prospect of irreparable harm. Because neither the merits nor the equitable considerations favored EOG, we reverse.

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