Abrams Centre National Bank, a National Banking Association v. Farmer, Fuqua & Huff, P.C., F/K/A Farmer, Fuqua, Hunt & Munselle, P.C., a Texas Professional Corporation

CourtCourt of Appeals of Texas
DecidedOctober 27, 2005
Docket08-05-00140-CV
StatusPublished

This text of Abrams Centre National Bank, a National Banking Association v. Farmer, Fuqua & Huff, P.C., F/K/A Farmer, Fuqua, Hunt & Munselle, P.C., a Texas Professional Corporation (Abrams Centre National Bank, a National Banking Association v. Farmer, Fuqua & Huff, P.C., F/K/A Farmer, Fuqua, Hunt & Munselle, P.C., a Texas Professional Corporation) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Abrams Centre National Bank, a National Banking Association v. Farmer, Fuqua & Huff, P.C., F/K/A Farmer, Fuqua, Hunt & Munselle, P.C., a Texas Professional Corporation, (Tex. Ct. App. 2005).

Opinion

COURT OF APPEALS

EIGHTH DISTRICT OF TEXAS

EL PASO, TEXAS


)

ABRAMS CENTRE NATIONAL BANK,         ) 

a National Banking Association,                      )                  No. 08-05-00140-CV

                                    Appellant,                        )                             Appeal from

v.                                                                          )                  298th District Court

FARMER, FUQUA & HUFF, P.C., f/k/a           )                  of Dallas County, Texas

Farmer, Fuqua, Hunt & Munselle, P.C., a           )

Texas Professional Corporation,                          )                  (TC# 02-01573)

                                    Appellee.                          )


O P I N I O N


            We address today the liability of an accounting firm for negligent misrepresentation in audit reports. The trial court granted summary judgment in favor of the firm, finding that no duty was owed. We affirm the trial court’s judgment.

FACTUAL SUMMARY

            ESS College of Business, Inc. was a for-profit business college located in Dallas, Texas and directed by Jan V. Friedheim. The College trained students to work as secretaries, paralegals, and administrative assistants. Most of the students received financial aid through federal programs which were administered by the Department of Education (DOE). In fiscal years 1999 and 2000, the DOE imposed the Ninety Percent Rule, which prohibited the College from deriving more than 90 percent of its revenue from federal funding.

            Although the College received federal funding for its programs, it also borrowed money from various lenders in 1998, 1999, and 2000. On November 5, 1998, it incurred the maximum credit line of $950,000 from Chase Bank of Texas, whose predecessor was Texas Commerce Bank (Chase). In March 1999, Abrams Centre National Bank (Abrams) replaced Chase as the lender for the 1998 debt. The $950,000 debt was rolled into a new seven-year term loan of $1,000,000 which was guaranteed by the Small Business Administration. Abrams also provided the College with a $300,000 credit line on April 22, 1999. The $300,000 credit line was renewed on April 22, 2000 and again on September 29, 2000. At that point, the credit line was increased by $200,000. On January 22, 2001, Abrams loaned an additional $250,000. All of the promissory notes were guaranteed by Jan V. Friedheim and her husband and secured by liens on personal property which primarily consisted of the College’s accounts receivable for funds due under federal educational programs for student loans.

            The College hired Farmer, Fuqua & Huff, P.C. as an independent auditor. Farmer audited the College at fiscal year end in 1998, 1999, and 2000. The audits were performed in compliance with DOE requirements. The College informed Farmer that copies of the audit would be sent to Chase as required by their line of credit.

            Following an open audit by the DOE in July 2000 indicating a high default rate on Perkins loans, the College was placed on provisional certification. When a school is placed on provisional certification, the DOE can take action without allowing for due process. The College never notified Abrams that it had been placed on provisional certification. The DOE placed the school on “reimbursement status” in December 2000 for failure to comply with the Ninety Percent Rule. While on reimbursement status, the College could only obtain Title IV reimbursement by submitting complex documentation every thirty days showing what funds had been earned during the prior period. As a consequence, the school suffered an adverse affect on its cash flow. ESS sought additional funds from Abrams and it agreed to the two-month short term loan of $250,000 in January 2001.

            On March 27, 2001, the DOE revoked the school’s provisional certification to participate in Title IV programs. ESS ceased operations, defaulted on all three loans to Abrams, and filed for bankruptcy. Because all of the loans were guaranteed by the Friedheims, Abrams filed suit against both of them. Abrams obtained a judgment for $1,600,000. This judgment remains unsatisfied.

            Abrams then filed suit against the accounting firm for negligent misrepresentation, claiming Abrams had relied on the financial status of the school as reflected in the audits when it loaned money to ESS. Farmer moved for summary judgment, contending that Abrams failed to establish that the firm knew Abrams would receive and use the audits in deciding whether to make the loans. Farmer relied upon the Restatement (Second) of Torts, contending that Texas follows Section 552 without reservation. Abrams responded that there was genuine issue of material fact as to whether the firm should have known its reports would be relied upon by Abrams. The trial court granted summary judgment with regard to the January 2001 loan because the evidence established as a matter of law that Abrams had not justifiably relied on the audit report. In denying summary judgment as to the March 1999 and the September 2000 loans, the trial court determined that the Restatement was inconsistent with Blue Bell, Inc. v. Peat, Marwick, Mitchell & Co., 715 S.W.2d 408, 412 (Tex.App.--Dallas 1986, writ ref’d n.r.e.). In Blue Bell, the Dallas Court of Appeals held accountants are liable to third parties under the Restatement if the accountant knew or should have known they would receive information. Farmer unsuccessfully argued that Blue Bell was overruled by the Texas Supreme Court’s decision in McCamish, Martin, Brown & Loeffler v. F.E. Appling Interests, 991 S.W.2d 787, 788 (Tex. 1999). It then filed an interlocutory appeal to the Dallas Court of Appeals pursuant to Tex.Civ.Prac.&Rem.Code Ann. § 51.014(d)(Vernon Supp.2004-05). The court denied the application. Farmer then filed a motion for reconsideration of the partial denial of summary judgment in the trial court. This motion was based upon Compass Bank v. King, Griffin & Adamson, P.C., 388 F.3d 504 (5th Cir. 2004) and Tara Capital Partners I, L.P. v. Deloitte & Touche, L.L.P., No. 05-03-00746-CV, 2004 WL 1119947 (Tex.App.--Dallas May 20, 2004). The trial court entered a final summary judgment on February 9, 2005.

STANDARD OF REVIEW

             In a traditional summary judgment proceeding, the standard of review on appeal is whether the successful movant at the trial level carried the burden of showing that there is no genuine issue of material fact and that judgment should be granted as a matter of law. Lear Siegler, Inc. v. Perez, 819 S.W.2d 470, 471 (Tex. 1991); Duran v. Furr’s Supermarkets, Inc., 921 S.W.2d 778, 784 (Tex.App.--El Paso 1996, writ denied).

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Abrams Centre National Bank, a National Banking Association v. Farmer, Fuqua & Huff, P.C., F/K/A Farmer, Fuqua, Hunt & Munselle, P.C., a Texas Professional Corporation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/abrams-centre-national-bank-a-national-banking-association-v-farmer-texapp-2005.