Gilbert Wheeler, Inc. v. Enbridge Pipelines (East Texas), L.P.
This case addresses the proper method for compensating a landowner for the destruction of trees on their property. Gilbert Wheeler, Inc. (Wheeler) sued Enbridge Pipelines, L.P. (Enbridge) for breach of contract and trespass after Enbridge destroyed several hundred feet of trees while constructing a pipeline, violating an agreement to use an underground boring method. The Texas Supreme Court clarifies the application of the temporary-versus-permanent injury distinction to real property damages, holding it applies to both tort and contract claims and is a question of law for the court. The Court confirms two exceptions to general damage rules: the economic feasibility exception, deeming the injury permanent due to restoration costs significantly exceeding market value diminution, and the intrinsic value of trees exception, allowing recovery for ornamental and utilitarian value even with nominal market value loss. The Supreme Court reversed the court of appeals' judgment and remanded the case to address remaining issues consistent with this opinion.