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STEPHENS PRODUCTION COMPANY v. LARSEN

Citations: 394 P.3d 1262; 2017 OK 36; 2017 WL 1900492; 2017 Okla. LEXIS 38

Court: Supreme Court of Oklahoma; May 9, 2017; Oklahoma; State Supreme Court

Original Court Document: View Document

Narrative Opinion Summary

In this case, Stephens Production Company pursued a condemnation action under Oklahoma's Underground Storage of Gas statutes to acquire easements for a natural gas storage facility impacting approximately 900 acres in Haskell County. The primary legal issue involved determining just compensation for the landowner, Mr. Larsen, who contested the compensation amount set by the trial court at $9,000, compared to his expert's valuation of $419,000. The Oklahoma Corporation Commission had previously approved the use of the Hunton Formation for gas storage, deeming it in the public interest. Procedurally, after a non-jury trial, the trial court's decision was upheld by the Court of Civil Appeals and later affirmed by the Oklahoma Supreme Court. The Supreme Court emphasized the importance of public welfare in underground gas storage projects. The ruling highlighted the application of general condemnation principles, requiring fair market value assessments without speculative valuation. The court's decision reflected a lack of active market demand for underground gas storage, thereby considering the property's highest and best use as its existing natural resource and agricultural purposes. All justices concurred in affirming the trial court's determination of just compensation.

Legal Issues Addressed

Burden of Proof in Valuation Disputes

Application: The landowner had the burden to demonstrate the fair market value of the property once the validity of the taking was established, which he failed to do.

Reasoning: The burden shifts to the landowner to demonstrate fair market value once the validity of the taking is established, defined as the price a willing buyer would pay to a willing seller.

Condemnation for Underground Storage of Gas

Application: The case involves the condemnation of property for underground gas storage, emphasizing public welfare as outlined in Oklahoma statutes.

Reasoning: Stephens Production Company initiated a condemnation action under Oklahoma's Underground Storage of Gas statutes to acquire easements for an underground natural gas storage facility in Haskell County.

Deference to Trial Court Findings

Application: The trial court's findings were upheld as they were supported by competent evidence, warranting deference similar to a jury's verdict.

Reasoning: In a non-jury trial, the findings of the trial court are treated with the same weight as a jury's verdict, allowing for deference to the court’s assessments of witness credibility and evidence.

Highest and Best Use in Property Valuation

Application: The court found the highest and best use of the property to be its existing natural resource and agricultural purposes due to lack of market demand for gas storage.

Reasoning: The property's highest and best use remained its existing natural resource, agricultural, and recreational purposes.

Just Compensation in Condemnation Proceedings

Application: The trial court determined just compensation based on fair market value, aligning with general condemnation principles that prohibit speculative valuation.

Reasoning: The trial court determined just compensation at $9,000. The trial court employed standard condemnation principles to assess the fair market value of the easements taken.