Adrienne Marco v. Kurt Kirkman

CourtCourt of Appeals of Texas
DecidedJune 26, 2026
Docket03-24-00133-CV
StatusPublished

This text of Adrienne Marco v. Kurt Kirkman (Adrienne Marco v. Kurt Kirkman) 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
Adrienne Marco v. Kurt Kirkman, (Tex. Ct. App. 2026).

Opinion

TEXAS COURT OF APPEALS, THIRD DISTRICT, AT AUSTIN

NO. 03-24-00133-CV

Adrienne Marco, Appellant

v.

Kurt Kirkman, Appellee

FROM THE COUNTY COURT AT LAW NO. 2 OF TRAVIS COUNTY NO. C-1-CV-22-003352, THE HONORABLE ERIC SHEPPERD, JUDGE PRESIDING

MEMORANDUM OPINION

Appellant Adrienne Marco, a landlord, appeals from the trial court’s judgment,

following a bench trial, finding her liable for bad-faith retention of a security deposit belonging

to her former tenant, appellee Kurt Kirkman. In six issues on appeal, Marco asserts that (1) a

cause of action for bad-faith retention of a security deposit “cannot prevail” without a statutory

presumption of bad faith; (2) the evidence is insufficient to establish the statutory presumption

that Marco acted in bad faith; (3) without the statutory presumption, there is insufficient

evidence to prove that Marco acted in bad faith; (4) there is insufficient evidence that Marco

failed to show that she acted in good faith to rebut the statutory presumption; (5) there is

insufficient evidence that Marco failed to prove that her retention of the security deposit was

reasonable; and (6) the trial court abused its discretion in its award of attorney’s fees. We will

modify the trial court’s judgment relating to appellate attorney’s fees and affirm in part the judgment as modified. We reverse in part and remand the trial court’s judgment relating to

attorney’s fees for non-attorney staff.

BACKGROUND

In 2019, Kirkman leased a house in south Austin from Marco. The lease

agreement required Kirkman to provide Marco with a security deposit of $2,400 and an

additional pet security deposit of $350 for his dog, Bubbles. The agreement made Kirkman

“responsible for clogged sinks, toilet, shower tub, and garbage disposal, all kitchen appliances,

including [the] refrigerator ice maker”; responsible for changing the AC filters on a monthly

basis; responsible for maintaining the yard at his own expense; and required him to repair any

damages to the property “beyond normal wear and tear,” which the lease defined as

“deterioration that occurs without negligence, carelessness, accident, or abuse.”

The lease ended in June 2022. Thirty days after Kirkman surrendered possession,

Marco emailed Kirkman the following itemized list of deductions from his security deposit:

2 Replace six window blinds damaged by dog $425.00 Sheetrock Patches - damaged walls and excessive nail holes $275.00 Paint patched walls $1,200.00 Replace and install laundry room door $250.00 Paint trim on excessive dings on door jams and window sills damaged by dog $360.00 Paint front door and trim due to scratches and excessive nail holes $125.00 Replace dead boxwood shrub $200.00 Removal of tree encroaching on property $300.00 Tighten loose toilet $75.00 HVAC repair due to unchanged filter $255.00 Replace oven and stove lightbulbs $60.00 Repair discolorations in laminate and wood floors $500.00 Sand and refinish permanently damaged deep marks and scratches on hardwood floors $3,900.00

Total Deductions $7,925.00

The email concluded, “These deductions were made in accordance with your lease agreement

and in compliance with [the] Texas Property Code. The original deposit did not cover all costs.

The remaining balance owed is $5,175.00.”

Shortly thereafter, Kirkman hired counsel and demanded the return of his security

deposit. In the demand letter, counsel wrote,

On July 29, 2022, you sent what purports to be an itemization of damages to the property caused by Mr. Kirkman. We contest these amounts. Please provide receipts for the materials and repairs, as well as pictures of the damages. At this time, we have no reason to believe any of the amounts on your list are valid. In fact, you have a reputation for retaining security deposits on questionable grounds.

Accordingly, we hereby demand a full refund of my client’s security deposit in the amount of $2,750. We demand an additional amount of $850 for the legal fees my client has incurred in reclaiming the security deposit. Of course, the fees are expected to rise should this matter not be resolved immediately.

....

3 In the event you choose not to refund the security deposit by 5:00 p.m. on August 16, 2022, then my client instructs me to file a bad faith retention lawsuit pursuant to TEXAS PROPERTY CODE § 92.109. If that is necessary, Mr. Kirkman will be entitled not only to the security deposit and his attorney’s fees, but also to $100 and three times the wrongfully withheld portion of the security deposit.

Marco did not respond to the letter by the deadline, and Kirkman filed suit for bad-faith retention

of the security deposit. Marco filed a general denial and a counterclaim for breach of contract

and later filed a no-evidence and traditional motion for summary judgment, which the trial court

denied. The case proceeded to a bench trial.

Marco and Kirkman were the only witnesses to testify at trial. Kirkman testified

that the rental property was an “older home,” built in 1950 or 1951. He recounted that he had

numerous issues with the house when he first moved in, including lights that were not working,

“an issue with the water pressure,” no hot water, a bathroom door that would not close

completely, an ice maker that was not working, grass not growing in the yard, and an oven that

would not turn on. Kirkman communicated with Marco about some of these issues. The lack of

hot water turned out to be Kirkman’s fault—he did not turn on the gas upon moving in, and this

was also the reason that the oven was not working. Marco expressed surprise about the absence

of grass, believing that seed had been planted before Kirkman moved in. Nothing was done

about the ice maker, which was Kirkman’s responsibility under the terms of the lease.

Kirkman explained that the heater in the home “was a constant issue” and that he

could “only use it two to three times a day for approximately an hour. If you used it longer, it

would eventually shoot out cold air, and if you used it too soon between those times, it wouldn’t

work at all.” The heater eventually stopped working during Winter Storm Uri in February 2021.

Later, in September 2021, when the temperature outside was “well over 100 degrees,” the air

4 conditioner in the house stopped working. Kirkman told Marco about this on a Friday night, but

Marco told him on Saturday that her HVAC technician was unavailable to come out to the

property until Monday. Kirkman then contacted his own HVAC technician to examine the air

conditioner, and this person told Kirkman that he could fix the issue in one to two hours for

approximately $200 to $300. However, when Kirkman told Marco about this, she “got very

defensive saying that nobody could go into the house . . . to do any sort of work or even diagnose

a problem without her consent,” and she denied the technician permission to do the work. As a

result, Kirkman had to stay in an Airbnb until the air conditioner was fixed.

Kirkman believed that when he moved out of the house, the condition of the

property was better than when he had moved into it. He had built a new fence around the yard

that he paid for out of his own pocket, and he also paid for the installation of a new toilet because

the old toilet was “extremely small,” “loose,” and had “issues in regards to flushing,” with

“anything you put into the toilet” having a tendency to clog. Kirkman communicated with and

received permission from Marco to install both the new fence and the new toilet.

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