Valero Energy General Counsel Rich Walsh watched in astonishment in 2022 and 2023 as major petroleum-related companies were silent as the Environmental Protection Agency allowed California to set more stringent fuel admission standards than required by federal law.
“This was an existential threat to our business and hundreds of other businesses, and I was shocked that no one else wanted to take it on,” Walsh told The Texas Lawbook.
The EPA and the U.S. National Highway Traffic Safety Administration granted California a waiver that, in essence, mandated that automotive manufacturers must produce electric vehicles instead of traditional internal combustion engine vehicles. The California regulations would force consumers to purchase vehicles that run on electricity instead of liquid fuels.
“Although Valero has historically not taken the lead on this type of litigation, Mr. Walsh led the charge to round up a smaller coalition and one trade association to file lawsuits challenging these regulations,” Valero Senior Managing Counsel Megan Quinn said.
On June 20, 2025, Walsh’s efforts paid off when the U.S. Supreme Court handed Valero a sweeping victory.
“Sometimes it is very evident when we are very right, and I knew from the start that this was one of those times,” Walsh said.
The win at the Supreme Court was only one of Walsh’s tremendous successes in 2024 and 2025.
As a result, the Association of Corporate Counsel’s San Antonio Chapter and The Lawbook have named Walsh as the recipient of the 2025 San Antonio Corporate Counsel Award for General Counsel of the Year for a Large Legal Department (21 or more lawyers).
Walsh and 11 other San Antonio area general counsel will be honored on Nov. 6 at the first-ever San Antonio Corporate Counsel Awards ceremony hosted by ACC and The Lawbook.
Premium Subscriber Q&A: Walsh addresses “nuclear verdicts” and what outside counsel needs to know about him.
“Mr. Walsh has played a pivotal role in shaping Valero’s legal strategy across multiple domains, both domestically and internationally,” said Quinn, who nominated Walsh for the award. “His creativity and ability to think strategically is unmatched. He has made a lasting impact at Valero, throughout communities and in the lives of those around him. His leadership has been instrumental in navigating complex legal landscapes during major corporate transactions, political and regulatory shifts.”
“Mr. Walsh is known for his collaborative leadership style, deep legal acumen and commitment to corporate integrity and community,” she said. “He challenges those around him to think critically, creatively and develop outside-the-box solutions.”
Dowd Bennett partner James Bennett, who has worked with Valero on critical matters for more than two decades, said Walsh is “attuned to the need to find solutions that were best for the communities where Valero operated, the company’s employees, its shareholders and the government regulators whom he works with very effectively.”
“Rich is unmatched as a creative thinker, and his judgment has led to remarkable achievements by Valero and the team he has built,” Bennett said. “He identifies novel approaches to sometimes long-standing issues where the conventional wisdom has never worked before. He has extremely good instincts and, equally importantly, trusts them. He is a great general counsel because he is thoughtful and extremely effective at setting strategic goals and also identifying where his personal time is most valuable.”
Hired by Valero as an in-house counsel in 1999, Walsh was promoted to general counsel in 2020.
“My job now is like being the Oracle of Delphi — I have an incredibly competent team, so by the time a problem gets to me, its intractable,” Walsh said. “So, I hold audiences, they present their dilemmas to me, and I give guidance or chart a course. The only difference is I don’t require incense or offerings.”
Walsh oversees a legal department of 40 attorneys and 25 other professionals. The company has added the duties of risk management, compliance, insurance, governmental affairs, ESG and health, safety and environment to Walsh’s portfolio and the 158 employees in those departments.
Quinn said that Walsh has scored numerous achievements beyond engineering the historic Supreme Court victory, including:
- Developing a leading government relations team at the international, federal and state levels;
- Growing Valero’s PAC to become a very influential voice in the policy arena;
- Creating a best-in-class ESG engagement process, developing an innovative environmental and safety audit program, putting in place one of the first environmental justice policies in the industry; and
- Leading the most successful United Way campaign in company history, raising more than $21 million.
Justice Lori Massey Brissette, a former corporate executive at USAA and Northwestern Mutual who was appointed to the Texas Fourth Court of Appeals last year, said that Walsh helped “mold me into the kind of attorney and judge that I am today.”
“Rich would ensure that the company understood the facts, would consider the risk and potential liability and would bat around with me the legal issues to be addressed,” said Justice Brissette, who represented Valero when she was in private practice. “Having that kind of character at the helm of a major corporate legal department is critical.”
Walsh’s Path to Law & Valero
Walsh was born in Downey, California, a community about a dozen miles southwest of downtown Los Angeles.
“But we reversed Grapes of Wrath and moved back to where my mother grew up in Oklahoma,” he said. “So, I claim Oklahoma as the place where I grew up. My mother worked a lot of jobs over her life, but up until a couple months before her recent passing, she was still employed organizing events at Astro Bowl on Austin Highway.
Walsh’s first job came when he was 16 managing the pet department at Walmart. He had plans to move into management but was informed that he needed a college education first.
He first attended night school at Tulsa Junior College and then the University of Oklahoma, where he initially studied pre-med.
“But then I discovered that I didn’t like working with blood,” he said. “So, I changed course. I grew up very poor, and I was very driven to succeed because of that.”
After earning his bachelor’s degree from OU, Walsh went to work for Williams Pipeline as a pipeline operator. But he kept remembering that he had taken the LSAT before graduation, and he scored very well.
He decided to return to OU for law school. There he met his wife, Georgia, who became a senior lawyer drafting legislation for Texas Senator Phil Gramm.
After graduating from OU with his law degree in 1992, he accepted a position with Phillips Petroleum in its Oklahoma oil and gas section.
The position lasted half of a day.
“I walked in for my first day of work and the receptionist was crying,” he said. “She told me they had all been laid off. They were closing the office the very day I started.”
Walsh walked to the office where he had been assigned and found a “welcome basket” that included a Phillips coffee cup. Then came instructions to relocate to Phillips HQ to work in the litigation department.
Over the next few years with Phillips, Walsh worked in Venezuela, Norway and the United Kingdom.
In 1999, he joined the legal department at Valero and has steadily moved up the ranks.
“I was looking to come back to the U.S. after having worked internationally,” he said. “I started out as one of two in the litigation, labor and regulatory group at Valero.”
Walsh said his biggest challenges at Valero “are confidential and privileged, but clearly, navigating the company through COVID and the pretty significant external pressures that are imposed on companies these days.”
Two dates in 2025 certainly standout from the rest.
April 23 was when Walsh, for the first time in his career, stepped inside the U.S. Supreme Court to hear his lawyers from Sullivan & Cromwell argue the case against the EPA over the California car emission restrictions.
“I was amazed at how close you are to the justices,” he said, referring to the courtroom. “It is much more intimate than I imagined. And I had never been in a place where 100 people sat so absolutely quiet.”
Valero had filed the lawsuit under the name of its subsidiary, Diamond Alternative Energy. The original complaint was filed in the U.S. Court of Appeals for the D.C. Circuit, as required by the U.S. Clean Air Act, and challenged the EPA’s decision during the Biden administration to allow California to set its own standards for vehicle emissions and electric cars.
The legal argument was that the federal government had exceeded its authority to grant California the exception, which they argued would have cost the fuel industry billions of dollars annually.
The D.C. Circuit rejected the lawsuit, claiming Valero did not have standing to challenge the EPA’s decision.
Valero appealed and the Supreme Court granted certiorari.
“The government has tilted the playing field and foreclosed us from being able to freely sell our product,” Sullivan & Cromwell partner Jeffrey Wall, who represented Valero, told the justices.
As oral argument concluded, Chief Justice John Roberts recognized retiring U.S. Deputy Solicitor General Edwin Kneedler for presenting a record 160th argument before the nation’s highest court.
“I had a pretty good day,” Walsh said. “I got sworn in at the U.S. Supreme Court. We argued our case, but I got to watch a standing applause led by the justices for a solicitor general of the U.S. who had just given his final argument — albeit against us — before the court. [Kneedler] holds the record for the most cases argued before the U.S. Supreme Court and served through numerous administrations. That was pretty awesome.”
But June 30, Walsh acknowledges, was an even better day.
The Supreme Court, in a 7-2 decision, said the appeals court had wrongly dismissed Valero’s challenge to the EPA’s exemption.
“The government generally may not target a business or industry through stringent and allegedly unlawful regulation, and then evade the resulting lawsuits by claiming that the targets of its regulation should be locked out of court as unaffected bystanders,” Justice Brett Kavanaugh wrote for the majority.
Christopher Carroll, a partner at Kennedys who has worked with Walsh over 17 years, said the Valero GC has a creative intelligence that is rare.
“With the size and complexity of a corporation like Valero, the issues Rich confronts on a daily basis are varied and fraught with challenges and difficulties,” Carroll said. “Valero is at the apex of the energy industry in no small part because of how Rich deals with all those challenges and difficulties.”
Valero Litigation Section Chief Alex Miller said that Walsh’s “strategic vision” is what sets him apart.
“When analyzing an issue, Rich doesn’t just think several steps ahead, he approaches each issue in the context of its broader impact on business dynamics and long-term strategy, often weaving in references to historic battles,” Miller said. “Working with Rich keeps me sharp and has made me a stronger strategic thinker.”
Mike Eaves, a partner at Calvert Eaves Clarke & Stelly in Beaumont, said Walsh is a “formidable adversary when it comes to protecting Valero’s interests in the legal arena,” but he said Walsh also “cultivates relationships with opponents with an eye toward the larger picture of what he is attempting to ultimately accomplish.”
“For example, prior to Valero’s acquisition of the Port Arthur refinery, the facility’s previous owners were constantly being attacked, harangued and sued by numerous civic groups based on a myriad of real and/or perceived environmental issues,” Eaves told The Lawbook. “Most of these complaints were unfounded, and they were therefore defended aggressively by the prior refinery owners in numerous multi-party legal actions. This endless stream of lawsuits only led to further frustration on the part of the company and ever-increasing acrimony with the community in a continuous Boolean Loop of litigation.”
“After Valero acquired the facility, Rich studied the situation and the issues involved,” he said. “He then reached out to local community activists and was able to forge an amicable — and litigation-free — relationship built on trust and mutual respect, and that peaceful relationship between Valero and the Port Arthur community exists to this day.”
“Rich is one of the smartest people I’ve ever met. In addition to being a brilliant attorney and a shrewd legal strategist, he takes ‘thinking outside the box’ to an entirely new level; it is an ability that has served him well over the years as Valero’s general counsel,” Eaves said.
Lawyers who work with Valero said Walsh has built an incredible legal team and he trusts the team to execute on his vision.
“Rich takes the time to know each individual person on his team at a personal level, including their strengths and aspirations for their own development,” Bennett of Dowd Bennett said. “This leads to a collaborative approach where every member is playing to their greatest strengths.”
“Rich has seen it and done it all in his industry, starting with going to law school at Oklahoma, to studying at Oxford in England, and practicing law in Norway,” he said. “Not a bad run for someone who’s best stories are still about an early job running the live animal sales department at his local Wal-Mart. He remembers where he came from, as you can also see with his wonderful family.”
Fun Facts: Rich Walsh
- Favorite book: The Bible, because it leads to salvation. I also like the Brandon Sanderson Mistborn series, well anything by Brandon Sanderson. And I love Dune.
- Favorite movie: Star Wars. Classic good versus evil. So great when I was young, and still good today.
- Favorite vacation: Hunting in Africa.
- Favorite restaurant: La Fogata
- Hero in life: I don’t have a single hero, I was never that lucky. My mom was a big inspiration, my wife is as well. I had an uncle, Don Foley, that was kind of my career hero.