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Great Plains Equipment, Inc. v. Koch Gathering Systems, Inc.

Citations: 45 F.3d 962; 1995 WL 54708Docket: 93-09069

Court: Court of Appeals for the Fifth Circuit; February 24, 1995; Federal Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

The case before the United States Court of Appeals, Fifth Circuit, involves two lawsuits by Great Plains Equipment, Inc. (GPE) and Great Plains Pipeline Construction, Inc. (GPP) against Koch Gathering Systems, Inc. (Koch). GPE sought damages for destroyed equipment, and GPP claimed breach of contract. Koch removed the cases to federal court based on diversity jurisdiction and counterclaimed for liquidated damages. The district court consolidated the cases, and the jury ruled in favor of GPE and GPP. Koch raised a Batson challenge regarding jury selection, alleging racial discrimination, but failed to rebut the race-neutral justification. The appeal also addressed contractual obligations, with the jury attributing responsibility for construction delays to Koch's failure to secure necessary permits, resulting in damages awarded to GPP. On property damage, the court upheld the jury's valuation of GPE's equipment, despite Koch's objections regarding evidence admissibility. The appellate court found no reversible error in the district court's decisions, affirming the jury's verdicts and awards in favor of GPE and GPP.

Legal Issues Addressed

Batson Challenge in Jury Selection

Application: Koch asserted a prima facie Batson violation based on the striking of the only African-American juror, but failed to demonstrate the proffered race-neutral reason was pretextual.

Reasoning: Koch asserts a prima facie Batson violation based on three factors: the striking of the only African-American juror, the lack of distinguishing information about the juror during voir dire, and the race of Koch's trial counsel, N. Sue Allen, who is African-American.

Contractual Obligations and Delay Damages

Application: The jury found Koch Gathering Systems, Inc. breached its contractual obligation by failing to secure necessary rights-of-way, resulting in delays and awarding damages to GPP.

Reasoning: The jury found in favor of GPP, indicating Koch failed to provide necessary rights-of-way and awarded GPP $228,324.94 for additional costs incurred from delays.

Parol Evidence Rule

Application: Testimony regarding an alleged prior oral promise was admitted despite Koch's objection, but the court found it did not affect Koch's substantial rights.

Reasoning: Koch objected to testimony about an alleged prior oral promise that no special restrictions would apply to GPP on the state right-of-way, arguing this violated the parol evidence rule since it was not included in the written contract.

Property Damage and Valuation

Application: The court found sufficient evidence to support the jury's verdict on property damage claims, affirming the valuation of GPE's equipment.

Reasoning: The court found sufficient evidence to support the jury's decision, assigning values of $20,000 for the J-40 and $160,000 for the 247.

Removal to Federal Court Based on Diversity Jurisdiction

Application: Koch Gathering Systems, Inc. successfully removed both cases from Texas state court to federal court by citing diversity of citizenship.

Reasoning: Koch removed both cases from Texas state court to federal court, citing diversity of citizenship, and counterclaimed against GPP for liquidated damages for late completion of a pipeline.