Virginia Power Energy Marketing, Inc and Dominion Resources, Inc v. Apache Corporation
This case concerns a business dispute over force majeure clauses in a natural-gas supply contract between Apache Corporation (seller) and Virginia Power Energy Marketing, Inc. (VPEM), the purchaser. Following Hurricanes Katrina and Rita, Apache invoked force majeure and curtailed deliveries to VPEM, leading to a lawsuit. The trial court granted summary judgment for Apache, excusing its performance. On appeal, the court affirmed the summary judgment regarding deliveries to the Tennessee L-500 point, finding performance excused due to pipeline damage. However, it reversed and remanded the summary judgment concerning the Transco-65 delivery point, identifying a factual dispute regarding whether Apache's 'gas supply' was genuinely lost, especially given its spot-market sales and disproportionate deliveries to other customers.