Albert Lee Giddens v. Jarrett Huffman

CourtCourt of Appeals of Texas
DecidedAugust 2, 2005
Docket14-04-00709-CV
StatusPublished

This text of Albert Lee Giddens v. Jarrett Huffman (Albert Lee Giddens v. Jarrett Huffman) 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
Albert Lee Giddens v. Jarrett Huffman, (Tex. Ct. App. 2005).

Opinion

Affirmed and Memorandum Opinion filed August 2, 2005

Affirmed and Memorandum Opinion filed August 2, 2005.

In The

Fourteenth Court of Appeals

____________

NO. 14-04-00709-CV

ALBERT LEE GIDDENS, Appellant

V.

JARRETT HUFFMAN, Appellee

On Appeal from the County Civil Court at Law Number One

Harris County, Texas

Trial Court Cause No. 792,126

M E M O R A N D U M   O P I N I O N

Albert Lee Giddens appeals from a judgment entered against him in favor of Jarrett Huffman, awarding damages of $19,000.  Giddens raises five issues in which he asserts that the trial court erred in finding: that he was sued in the correct capacity; that the Statute of Frauds did not apply; that the evidence was sufficient to prove a standard referral fee in Pasadena, TX; and that $38,000 was the referral amount to be divided among the parties.  We affirm.  


                                                     Background

In 1998, Giddens and Huffman entered into an agreement whereby Huffman would begin to refer his personal injury cases to Giddens in exchange for a referral fee computed as a percentage of attorney=s fees recovered from the cases.  Huffman testified that the agreed-upon percentage of referral fees was 50%.  In July of 2000, Huffman referred LaWanda Barnhill to Giddens.  Giddens testified that at the time of the referral, he was unaware that Huffman had referred the case.  In June 2002, the Barnhill case settled for $115,000 and Giddens received 45%, or $51,750, in attorney fees.  Giddens did not pay Huffman a referral fee at the time the case settled. 

Some time later, Huffman discovered through Barnhill that her case had settled.  Huffman and John Morgan, a mutual acquaintance of Giddens and Huffman, then contacted Giddens and questioned him about the settlement of the Barnhill case.  During the course of the conversation, Giddens allowed that Huffman had Asome money coming on [the Barnhill case].@  Giddens did not state the exact amount that Huffman had Acoming@ during the conversation.  After further pressure from Huffman, Giddens eventually forwarded him a check in the amount of $5,175, or 10% of the total fee he received from the Barnhill case.  Huffman did not cash the check; instead, he responded with a demand letter, seeking 50% of the amount of attorney=s fees Giddens had received.  Huffman waited 30 days from the date of the demand letter and then filed suit for $25,875, or 50% of the attorney=s fees Giddens received from the Barnhill settlement. 

Following a bench trial, the court found that Huffman had sued Giddens in the proper capacity; that the Statute of Frauds did not apply; that 50% is the standard referral fee in Pasadena, Texas Aas between the parties@; and that the base amount of the settlement was $38,000.  On that basis, the trial court granted judgment against Giddens in the amount of $19,000.          


                                                        Capacity

In his first issue, Giddens argues that the trial court erred in finding that he was sued in the proper capacity as an individual; Giddens claims that he should have been sued as Albert Lee Giddens, P.C. This contention is essentially an attack on the legal sufficiency of the trial court=s finding that Giddens was sued in the proper capacity.  We review challenges to the sufficiency of the evidence under the usual standards of review.  See Volkswagon of Am. v. Ramirez, 159 S.W.3d 897, 903 (Tex. 2004); IKON Office Solutions, Inc. v. Eifert, 125 S.W.3d 113, 123B24 (Tex. App.CHouston [14th Dist.] 2003, pet. denied).

As part of Giddens=s original answer to Huffman=s claims, Giddens filed a verified denial pursuant to Tex. R. Civ. P. 93(2) alleging that he had not been sued in the proper capacity.  Giddens asserts that this pleading automatically created a defect of parties that was fatal because it went uncorrected by Huffman.  As support for the proposition that a failure to respond to a Rule 93(2) plea creates a defect of parties, Giddens cites Gunn v. Harris Methodist Affiliated Hosp., 887 S.W.2d 248, 249  (Tex. App.CFort Worth 1994, writ denied).  Gunn simply does not stand for such a proposition. 


In Gunn, the defendant hospital filed a sworn denial claiming that it was not liable in the capacity in which it was sued and, separately, that there was a fatal defect of the parties.  Id.  Contemporaneously, the hospital filed a summary judgment motion supported by summary judgment evidence asserting that it did not own or operate the premises on which the plaintiff was injured.  Id.  The plaintiff failed to timely respond to the summary judgment motion.  The defendant hospital did not prevail on the basis of merely filing a Rule 93(2) pleading to which the plaintiff did not respond. 

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Related

Volkswagen of America, Inc. v. Ramirez
159 S.W.3d 897 (Texas Supreme Court, 2004)
IKON Office Solutions, Inc. v. Eifert
125 S.W.3d 113 (Court of Appeals of Texas, 2004)
Texas Gas Exploration Corp. v. Broughton Offshore Ltd.
790 S.W.2d 781 (Court of Appeals of Texas, 1990)
Niday v. Niday
643 S.W.2d 919 (Texas Supreme Court, 1982)
Seth v. Meyer
730 S.W.2d 884 (Court of Appeals of Texas, 1987)
Gunn v. Harris Methodist Affiliated Hospitals
887 S.W.2d 248 (Court of Appeals of Texas, 1994)
Anderson, Greenwood & Co. v. Martin
44 S.W.3d 200 (Court of Appeals of Texas, 2001)
Commercial Union Insurance Co. v. Martinez
635 S.W.2d 611 (Court of Appeals of Texas, 1982)
Peterson v. Reyna
908 S.W.2d 472 (Court of Appeals of Texas, 1995)
Peterson v. Reyna
920 S.W.2d 288 (Texas Supreme Court, 1996)
Pledger v. Schoellkopf
762 S.W.2d 145 (Texas Supreme Court, 1988)

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Bluebook (online)
Albert Lee Giddens v. Jarrett Huffman, Counsel Stack Legal Research, https://law.counselstack.com/opinion/albert-lee-giddens-v-jarrett-huffman-texapp-2005.