Enterprise Prods. Partners, L.P. v. Mitchell

340 S.W.3d 476 (2011)

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Enterprise Prods. Partners, L.P. v. Mitchell

Texas Court of Appeals

340 S.W.3d 476 (2011)

Facts

Dixie Pipeline Company (Dixie) (defendant) operated a 35,000-mile pipeline system, including a 1,300-mile span that passed through Mississippi and several other states. The Mississippi portion, built in 1960, ruptured in 2007, causing a large fire that killed two people, Mattie Mitchell and Nacquandrea Mitchell. The decedents’ beneficiaries (plaintiffs) sued Dixie and its managing partner, Enterprise Products Partners, L.P. (Enterprise) (defendant), in Texas state court asserting Texas tort claims. Dixie and Enterprise were both Delaware corporations with principal places of business in Houston, Texas. The pipeline system was entirely controlled and monitored from Houston. Only about five employees worked in Mississippi. Dixie and Enterprise moved to apply Mississippi law, rather than Texas law, because the accident occurred in Mississippi and all decedents and beneficiaries were Mississippi residents. Mississippi’s Tort Reform Act of 2004, capping noneconomic damages, was enacted to attract businesses to Mississippi. The trial court denied the motion, holding Texas law applied. Dixie and Enterprise filed an interlocutory appeal.

Rule of Law

Issue

Holding and Reasoning (Keyes, J.)

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