Refinery Holding Co., L.P. v. TRMI Holdings, Inc. (In re El Paso Refinery, L.P.)

302 F.3d 343 (2002)

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Refinery Holding Co., L.P. v. TRMI Holdings, Inc. (In re El Paso Refinery, L.P.)

United States Court of Appeals for the Fifth Circuit
302 F.3d 343 (2002)

  • Written by Rose VanHofwegen, JD
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Facts

TRMI Holdings, Inc. acquired an oil refinery in a spinoff transaction from its parent company, Texaco. The spinoff required TRMI to assume responsibility for environmental contamination at the refinery. TRMI transferred the refinery to El Paso Refinery, LP in a series of transactions documented by a purchase agreement and deed. Those documents contained covenants precluding subsequent owners of the refinery from seeking contribution from TRMI or compelling TRMI to remediate any environmental contamination. A subsequent owner of the refinery sought a declaratory judgment defining the parties’ responsibilities for contamination at the site. Several parties, including TRMI, brought successive appeals. TRMI argued that the restriction was enforceable either as a real covenant that runs with the land, or alternatively, as an equitable servitude.

Rule of Law

Issue

Holding and Reasoning (Garza, J.)

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