WY STATEWyoming Supreme Court
2020

Denbury Onshore, Llc and Denbury Resources Inc. N/K/A Denbury Inc. v. Apmtg Helium Llc

476 P.3d 1098Wyoming Supreme Court • Decided 2020Enforced

HOLDING

Denbury agreed to deliver helium to APMTG but failed to meet delivery obligations. Denbury claimed two force majeure events excused its non-performance: a contractor's failure to complete a processing plant and well failures from sulfur deposits. The Wyoming Supreme Court upheld the lower court's decision, finding force majeure applied for only 36 days out of the entire contract period. Denbury was ordered to pay APMTG over $35 million in liquidated damages and interest for the breach.

KEY FINDINGS

Force Majeure

Force majeure clauses are narrowly interpreted—you must prove the specific event directly caused your inability to perform, not just that problems existed during the contract period

Liquidated Damages

Contractor delays or equipment failures by third parties typically don't qualify as force majeure unless the contract specifically names them or they're truly unforeseeable acts of nature

Dispute Resolution

Liquidated damages clauses will be enforced even for large amounts if the court finds them reasonable; don't assume a judge will reduce them just because they're substantial

FULL COURT OPINION