Sandvick v. LaCrosse
Supreme Court of North Dakota
747 N.W.2d 519 (N.D. 2008)
Sandvick, Bragg, LaCrosse, and Haughton jointly purchased three oil and gas leases (the Horn leases) using credits in a company account, intending to resell them for profit before their five-year terms expired. Shortly before expiration, LaCrosse and Haughton (defendants) quietly purchased three functionally identical extension leases (the Horn top leases) in their own names, without informing or including Sandvick and Bragg (plaintiffs). Sandvick and Bragg sued for breach of fiduciary duty, but the district court found neither a partnership nor a joint venture existed and dismissed the claim.
Whether a joint purchase of a lease for the purpose of reselling it for profit constitutes a joint venture.