Al Aguilar v. Forrest Livingston

CourtCourt of Appeals of Texas
DecidedJanuary 11, 2005
Docket14-03-01312-CV
StatusPublished

This text of Al Aguilar v. Forrest Livingston (Al Aguilar v. Forrest Livingston) 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
Al Aguilar v. Forrest Livingston, (Tex. Ct. App. 2005).

Opinion

Reversed and Remanded and Opinion filed January 11, 2005

Reversed and Remanded and Opinion filed January 11, 2005.

In The

Fourteenth Court of Appeals

_______________

NO. 14-03-01312-CV

AL AGUILAR, Appellant

V.

FORREST LIVINGSTON, Appellee

_______________________________________________________

On Appeal from the County Civil Court at Law No. 3

Harris County, Texas

Trial Court Cause No. 790,185

O P I N I O N

Appellant, Al Aguilar, appeals the trial court=s denial of his motion for default judgment in his suit against appellee, Forrest Livingston, and the subsequent dismissal of the suit for want of prosecution.  Because we find that the trial court erred in denying appellant=s motion for default judgment, we reverse and remand.

Background


Appellant filed suit against appellee to recover for property damage sustained in an automobile accident.  Appellee was served on April 4, 2003; however, he did not answer the suit.  Appellant filed a motion for default judgment.  On October 1, 2003, the trial court denied the motion for default judgment.  Although the trial court did not state the reason for its ruling, appellant asserts that the trial court determined the return of service was defective.[1]

Meanwhile, the trial court issued a notice of a status conference and intent to dismiss for want of prosecution.  The order stated that the case would be dismissed for want of prosecution if, among other reasons, a party failed to appear for a status conference on November 4, 2003 or failed to notify the court coordinator that a motion for default was pending at least fourteen days prior to the status conference.  On November 5, 2003, the trial court entered an order dismissing the case for want of prosecution because the parties Ahaving been notified of the Status Conference . . . failed to appear.@  This appeal followed.

Denial of Motion for Default Judgment


In his first issue, appellant contends that the trial court erred in denying his motion for default judgment.  Ordinarily, the denial of a default judgment is an interlocutory order not subject to appeal.  See Tex. Civ. Prac. & Rem. Code Ann. ' 51.014 (Vernon Supp. 2004B05); see also Hines v. Flores, No. 09‑02‑519 CV, 2003 WL 1848656, at *1 (Tex. App.CBeaumont Apr. 10, 2003, order) (not designated for publication).  However, appellate courts have considered the denial of a default judgment when, as here, the denial is challenged in an appeal from a final judgment or order.  See Aguilar v. Alvarado, 39 S.W.3d 244, 247B48 (Tex. App.CWaco 1999, pet. denied); see also Thomas v. Univ. of Texas Med. Branch at Galveston, Nos. 01‑03‑00471‑CV, 01-03-00472-CV, 2004 WL 1516456, at *4 (Tex. App.CHouston [14th Dist.] July 8, 2004, no pet.) (not designated for publication); Holleman v. West End Cab Co., No. 07-99-0232-CV, 2000 WL 898003, at *2 (Tex. App.CAmarillo July 6, 2000, pet. denied) (not designated for publication).  These courts have reviewed the denial of a motion for default judgment under the abuse of discretion standard.  See Aguilar, 39 S.W.3d at 247B48; see also Thomas, 2004 WL 1516456, at *4; Holleman, 2000 WL 898003, at *2. 

While a determination of factual matters is left to the sound discretion of the trial court, a trial court=s failure to analyze or apply the law correctly is an abuse of discretion.  Walker v. Packer, 827 S.W.2d 833, 840 (Tex. 1992).  Here, the facts are undisputed because there is no appellee=s brief, see Tex. R. App. P. 38.1(f), and the return of service at issue is included in the record.  Therefore, we will determine whether the trial court failed to correctly analyze and apply the law to the facts.  See id.

At any time after a defendant is required to answer, the plaintiff may take a default judgment if the defendant has not previously filed an answer, and the citation with the officer=s return has been on file with the clerk for ten days.  See Tex. R. Civ. P. 239; Tex. R. Civ. P. 107.  Here, appellee did not file an answer, and the citation and return of service had been on file for ten days when appellant moved for a default judgment.

According to appellant, the trial court determined that the return of service is defective because it did not show the city and state of service.  However, the trial court=s order denying the motion for default judgment does not indicate that the trial court determined the return is defective, much less why it is defective.[2]  Nonetheless, ADefective Service@ is hand-written at the bottom of the citation, and ARet Defective Dwp 11-4@ is hand-written on the motion for default judgment. 

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Bluebook (online)
Al Aguilar v. Forrest Livingston, Counsel Stack Legal Research, https://law.counselstack.com/opinion/al-aguilar-v-forrest-livingston-texapp-2005.