Adrian Rafael Mejia v. Mobiloil Federal Credit Union

CourtCourt of Appeals of Texas
DecidedMarch 23, 2023
Docket09-21-00079-CV
StatusPublished

This text of Adrian Rafael Mejia v. Mobiloil Federal Credit Union (Adrian Rafael Mejia v. Mobiloil Federal Credit Union) 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.

Bluebook
Adrian Rafael Mejia v. Mobiloil Federal Credit Union, (Tex. Ct. App. 2023).

Opinion

In The

Court of Appeals

Ninth District of Texas at Beaumont

__________________

NO. 09-21-00079-CV __________________

ADRIAN RAFAEL MEJIA, Appellant

V.

MOBILOIL FEDERAL CREDIT UNION, Appellee __________________________________________________________________

On Appeal from the County Court of Law No. 1 Jefferson County, Texas Trial Cause No. 135149 __________________________________________________________________

MEMORANDUM OPINION

In this suit to recover a deficiency on a debt, Adrian Rafael Mejia,

the debtor, appeals from a judgment awarding Mobiloil Federal Credit

Union, the creditor, around $13,772 for the deficiency left on the loan.1

1For convenience, we have rounded all numbers mentioned in the opinion other than those we have quoted from exhibits in the record to whole numbers. Together with the contract damages award, the judgment the trial court signed includes additional awards for attorney’s fees, prejudgment and post-judgment interest, and costs of court. 1 In his first issue, Mejia contends that in the summary judgment

proceeding that led to the trial court’s judgment, the trial court erred in

granting Mobiloil’s combined traditional and no-evidence motion for

summary judgment for two reasons. First, he claims Mobiloil failed to

prove he was in default on his loan when Mobiloil accelerated his note.

Second, Mejia argues that a genuine issue of material fact exists on his

affirmative defense that Mobiloil failed to mitigate its damages by

demanding payment from the company that insured his vehicle against

damages before selling it at an auction, which he claims would have also

reduced the outstanding balance he owed Mobiloil on his loan.

In his second issue, Mejia argues the trial court erred in overruling

his objections to the affidavit of the president of Safety Adjusters, Inc.,

the company that repossessed and stored Mejia’s vehicle. The affidavit is

relevant to Mejia’s claim that his SUV was damaged by water due to

flooding after it was repossessed. In the affidavit, the president of Safety

Adjusters swore that while Mejia’s vehicle was in Safety Adjuster’s

possession, “[t]he condition of the vehicle, when it left Safety Adjusters,

Inc., was the same as when it was recovered by Safety Adjusters, Inc.”

2 Because the trial court did not err in granting Mobiloil’s combined

motion for summary judgment, we will affirm.

Background

After signing a Retail Installment Contract to obtain a loan, Adrian

Rafael Mejia bought a used SUV from Energy Country Ford. Mejia

financed $39,687 of the vehicle’s cost. Under his loan, Energy Country

Ford had the right to assign the Note to Mobiloil. No one disputes that

Mobiloil acquired the Note from the dealership where Mejia bought his

car.

The terms of Mejia’s loan required him to repay the loan (with

interest) in seventy-two monthly installments. Mobiloil also acquired a

security interest in Mejia’s SUV, and the loan’s provisions gave Mobiloil

a security interest in Mejia’s SUV to secure “all your promises in it.”

Under the loan, Mejia was in default upon failing to make an installment

payment “when it is due[.]” Mobiloil had other rights under the loan’s

provisions too, including the right to accelerate the loan on Mejia’s

default, demand payment in full, and repossess and sell the SUV.

The summary-judgment evidence shows that Mejia signed the

Retail Sales Contract in October 2018. The terms of the Retail Sales

3 Contract required Mejia to make monthly loan payments of $683, with

the first payment due on November 22, 2018. A payment was late if not

received by Mobiloil fifteen days after it was due. If more than fifteen-

days late, the agreement required Mejia to pay a late charge of five

percent of the scheduled payment.

Mejia made his first payment under the Retail Sales Contract—

which was due on November 22—on December 10, 2018. That made his

first payment late. Mejia’s payment history over the life of the loan before

Mobiloil accelerated the debt reflects that Mejia sometimes made his

payments outside the fifteen-day grace period and sometimes paid less

than the scheduled payment he owed on the debt.

Mejia made ten payments on the loan before August 29, 2019, when

Mobiloil declared the loan in default. As mentioned, Mejia’s December

2018 payment was more than fifteen-days late, but that payment didn’t

include the five percent late-charge penalty. Mejia’s April 2019 payment

was also late, and when he made that payment, he paid less than half his

regularly scheduled payment that month. While Mejia’s made his May

2019 payment on time, he didn’t pay the $683 under his payment

schedule for that month. Instead, he paid around half that amount. Had

4 Mejia made timely payments of $683 in the ten months before Mobiloil

accelerated the debt, Mejia would have paid around $6830 in principal

and interest on the loan, not including late charges and fees. When

Mobiloil accelerated the loan Mejia had paid Mobiloil just $6193 in

principal and interest on the loan, not including late charges and fees.

After Mejia failed to cure the deficiency, Mobiloil repossessed the

SUV. Mobiloil advised Mejia the SUV would be sold “sometime after

09/27/2019[,]” and that if Mejia needed to remove anything from the

vehicle, he should contact Safety Adjusters and arrange to remove his

possessions from the vehicle before it was sold. Mejia arranged to remove

his property from the SUV, and in an affidavit that Mejia filed just four

days before the trial court granted Mobiloil’s motion, Mejia swore:

When I reached the vehicle, I personally observed a water line indicating the vehicle had been partially submerged in water. In addition, when I observed the interior of the vehicle, the vehicle had moldy, wet smell and the interior of the vehicle was damp. My personal belongings had also been damaged by water.

In November 2019, Mobiloil advised Mejia that although it had sold

the SUV, it received less money from the sale than he owed on his loan.

According to Mobiloil’s letter, Mejia owed Mobiloil $13,797 after Mobiloil

5 had accounted for the proceeds from the sale ($23,200), the expenses

Mobiloil incurred for repossessing and selling the SUV ($750), and the

refund Mobiloil received from Energy Country Ford for the premium

Mejia paid on a GAP and Extended Warranty policy ($1,781), which

Mejia bought when he purchased the SUV from Energy Country Ford.

In March 2020, Mobiloil sued Mejia for breaching the Retail Sales

Contract. It sought to recover the amount it claimed Mejia owed it on the

loan ($13,772), prejudgment interest under the contract on that amount,

and attorney’s fees. 2 After Mejia answered, Mobiloil moved for summary

judgment, alleging the evidence showed Mejia defaulted on the loan and

that as of January 3, 2020, he owed Mobiloil $13,772 plus 7.5 percent

interest as provided by the contract. Mobiloil filed exhibits to support its

motion, including the affidavit of Shellye Kimler, Mobiloil’s records

custodian, and eight pages of records that Mobiloil kept in the regular

course of business on Mejia’s loan. Kimler swore that Mejia failed to pay

Mobiloil as agreed under the terms that applied to Mejia’s loan. She also

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Adrian Rafael Mejia v. Mobiloil Federal Credit Union, Counsel Stack Legal Research, https://law.counselstack.com/opinion/adrian-rafael-mejia-v-mobiloil-federal-credit-union-texapp-2023.