Valley View Angus Ranch v. Duke Energy Field Services

Duke (defendant), which held an easement on Valley View's (plaintiff) ranch, earlier sued Valley View in Oklahoma state court for unlawfully restricting Duke's access to the easement, winning a jury verdict Valley View never appealed. Valley View later sued Duke in federal court, alleging Duke's gas line through the easement had leaked and polluted the ranch's soil and groundwater, seeking damages for trespass, nuisance, and unjust enrichment; the district court granted Duke summary judgment, finding Valley View's claims barred because they should have been raised as compulsory counterclaims in the earlier suit. Valley View appealed.