Texas Court Deems Petroleum Engineer Qualified To Opine On Metallurgical Matters

Court: United States District Court for the Eastern District of Texas, Tyler DivisionJurisdiction: FederalCase Name: Woodbine Prod. Corp. v. Eagle Tubulars, L.L.C.Citation: 2017 U.S. Dist. LEXIS 181171

Facts

The plaintiff rented a work-string and two pipes from the defendant to clean a well. While the plaintiff was cleaning, the work-string got stuck in the well and the pipe parted. When the plaintiff tried to free the string, sections of the pipe became stuck in the well. The plaintiff filed a suit alleging the pipe and work-string were not fit for their purpose and not up to API standards. The plaintiff presented a petroleum engineer as an expert witness who intended to testify that the product did not meet API standards and that the pipe was defective. The defendant filed a motion to exclude the testimony of the expert.

Court’s Discussion

The defendant argued that the expert was not qualified to opine about the pipe at issue because he was not a metallurgical expert.

The plaintiff countered that because the expert was a petroleum engineer, he was more than qualified to opine on the issues at hand. The plaintiff pointed out that the expert had also researched the specifications involved in pipe string use. The court found that because the expert was a petroleum engineer with career experience in the industry and substantial experience working with pipes, he was qualified to testify in this case. The expert did not have to be a metallurgical expert to testify why the pipe in the issue had failed. Any lack of experience in the specifics of metallurgy went to the weight of his testimony, not the admissibility.

The defendant also argued that the expert applied an invalid method to reach his conclusions. The defendant asserted that the expert made a faulty comparison to another product and his report and that his deposition testimony simply restated his conclusions. The plaintiff contended that the expert’s opinion was reliable because he had significant experience in the pipe field and had enough knowledge about the pressure, force the pipe can hold. The expert provided opinions on the reasonable and customary standards with respect to pipe, API limits, and oil drilling operation. The testimony did not suffer from any analytical gap between the expert opinion and the bases on which he formed his opinion.

Held

The motion to exclude the expert’s testimony was denied. The court found that the expert’s methodology satisfied the standards of reliability and that the testimony would help the trier of fact understand the customary standards of the oil and gas industry, the pipes typical API specifications, and the pressure typically used on a pipe.