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Sasol North America, Inc. v. Bolton

103 So. 3d 1267 (2012)

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Sasol North America, Inc. v. Bolton

Louisiana Court of Appeal

103 So. 3d 1267 (2012)

Facts

Mr. and Mrs. Bolton (defendants) entered into a 30-year right-of-way agreement with Continental Oil Company for the construction and operation of a pipeline across the Boltons’ property. The agreement expired after Mr. Bolton’s death, and Continental’s successor to the right, Sasol North America, Inc. (Sasol) (plaintiff) sought to renew the right-of-way agreement with Mrs. Bolton. Mrs. Bolton and Sasol attempted to negotiate a renewal but failed to finalize an agreement. Sasol eventually sued Mrs. Bolton, claiming that Mrs. Bolton had made an oral offer to extend the right of way for an additional 30 years for $50,000 and that Sasol had accepted that offer. Mrs. Bolton denied that she had offered the renewal and claimed that she had rejected Sasol’s renewal request. Mrs. Bolton filed a motion for summary judgment, alleging that the right of way was an immovable under Louisiana law and that transfers of immovables were not valid unless made in writing. The trial court granted Mrs. Bolton’s motion. Sasol appealed.

Rule of Law

Issue

Holding and Reasoning (Pickett, J.)

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