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Reliant Energy Services Inc. v. Cotton Valley Compression LLC

Cotton Valley Compression LLC (Cotton Valley) brought a breach-of-contract action against Reliant Energy Services Inc. (Reliant) based on theories of actual and apparent agency by a third party, Westfield Oil & Gas Inc. (Westfield). The jury found in favor of Cotton Valley on both theories of agency and rejected Reliant's affirmative defense of quasi-estoppel. Thereafter, the trial court rendered judgment against Reliant on the jury verdict under the theory of apparent authority but granted Reliant's motion for judgment notwithstanding the verdict on the theory of actual authority. Both parties appealed. The trial court's judgment is affirmed. Houston's 1st Court of Appeals, No. 01-08-00148-CV, 02-10-2011

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OPINION

Cotton Valley Compression, L.L.C. (“Cotton Valley”) brought a breach-of-contract action against Reliant Energy Services, Inc. (“Reliant”) based on theories of actual and apparent agency by a third-party, Westfield Oil & Gas, Inc. (“Westfield”).*fn1 The jury found in favor of Cotton Valley on both theories of agency and rejected Reliant’s affirmative defense of quasi-estoppel. Thereafter, the trial court rendered judgment against Reliant on the jury verdict under the theory of apparent authority but granted Reliant’s motion for judgment notwithstanding the verdict on the theory of actual authority.

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