Amazon.com Services LLC v. Reginald Grant

CourtCourt of Appeals of Texas
DecidedDecember 10, 2024
Docket05-23-01306-CV
StatusPublished

This text of Amazon.com Services LLC v. Reginald Grant (Amazon.com Services LLC v. Reginald Grant) 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
Amazon.com Services LLC v. Reginald Grant, (Tex. Ct. App. 2024).

Opinion

Reversed and Rendered and Opinion Filed December 10, 2024

In The Court of Appeals Fifth District of Texas at Dallas No. 05-23-01306-CV

AMAZON.COM SERVICES LLC, Appellant V. REGINALD GRANT, Appellee

On Appeal from the County Court at Law No. 4 Dallas County, Texas Trial Court Cause No. CC-22-04274-D

MEMORANDUM OPINION Before Justices Pedersen, III, Smith, and Garcia Opinion by Justice Garcia Amazon.Com Services LLC (“Amazon”) appeals the $20,000 judgment

entered in favor of Reginald Grant (“Grant”) following a jury trial on Grant’s breach

of contract and fraud claims. In five issues, Amazon argues: (1) the trial court erred

in denying its JNOV because the economic loss rule and/or independent injury rule

foreclose Grant’s recovery for fraud, (2) the breach of contract claim forecloses the

fraud claim as a matter of law, (3) there is legally insufficient evidence of damages,

(4) the evidence is legally and factually insufficient to support a fraud finding, and

(5) the trial court erred in admitting Grant’s exhibit number 6. We conclude the evidence is insufficient to support the jury’s fraud finding.

We further conclude that the trial court erred in admitting exhibit 6, and

consequently the evidence is insufficient to support the amount of damages awarded

for breach of contract. We therefore reverse the trial court’s judgment, render

judgment for Grant on his breach of contract claim in the amount of $945.51, and

remand to the trial court for entry of a judgment awarding Grant $945.51, together

with prejudgment interest, post judgment interest, and costs allowable by law, to be

determined and calculated by the trial court.

I. BACKGROUND

Grant began working for Amazon in October 2018 as a warehouse associate.

In April 2021, he received an email from transportation area manager Kris Mixon

informing employees in the transportation department, including Grant, that

Amazon intended to standardize its shifts, and employees within the transportation

department would need to select one of the new shifts outlined in the email moving

forward. Grant understood Mixon’s email to mean one of the new shifts being

offered, Wednesday through Saturday from 4:00 p.m. to 2:30 a.m., was eligible for

a shift differential of $0.60 cents per hour (the “Shift Differential”).

Grant bid on the shift and was selected for the position. He began working the

new shift on or about June 11, 2021. When reviewing his paycheck approximately

one month later, Grant realized that his paycheck did not include the Shift

Differential.

–2– Grant asked Mixon about the issue. In response, Mixon submitted a ticket to

Human Resources on Grant’s behalf. Mixon received no response, so he submitted

an escalation ticket to Human Resources.

Mixon subsequently learned that no one on Grant’s shift was eligible for the

Shift Differential, so his email about the new shifts was in error. Mixon testified that

his email was never intended to mislead anyone into thinking that the Shift

Differential applied. Rather, his communication was “accidental.”

In January 2022, after Mixon moved to a different position within the

organization, Grant spoke with a different manager, George Wiley, about the Shift

Differential. Wiley confirmed to Grant that he was not entitled to the Shift

Differential because it did not apply to his shift. Nevertheless, Grant continued

working the shift.

Grant filed suit in the Justice Court alleging breach of contract, fraud, and

mental anguish and emotional distress. A jury found in favor of Grant, and the court

entered judgment awarding him $386.00. plus costs. Grant appealed to the County

Court and the case was tried to a jury.1

During trial, Amazon moved for directed verdict on the fraud claim as well as

the claim for mental anguish and emotional distress damages. The Court denied

Amazon’s motion. After permitting Grant to reopen his case to present evidence of

1 Grant appeared pro se at trial as he does on appeal.

–3– his alleged mental anguish and/or emotional distress, the Court granted Amazon’s

motion for a directed verdict on the claim for mental anguish and emotional distress

damages, but denied the motion as to fraud.

The jury was charged on both fraud and breach of contract. After

deliberations, the jury found: (1) a valid contract existed between Grant and

Amazon, (2) Amazon breached that contract “by failing to pay the 60 cent per hour

shift differential,” (3) Grant suffered $1,138.51 in damages relating to his breach of

contract, (4) Amazon committed fraud “by falsely representing a 60 cent pay

differential was available” for the shift Grant worked, and (5) Grant sustained

$20,962.00 in damages as a result of the fraud.2

The trial court entered final judgement in favor of Grant in the amount of

$20,000. Amazon filed a motion for JNOV, or alternatively, motion for new trial.

The motion was denied and this appeal followed.

II. ANALYSIS

A. Fraud

Amazon’s fourth issue argues the evidence is legally and factually insufficient

to support the judgment for fraud. We agree.

2 There is no explanation as to why the court reduced the $20,962.00 in fraud damages found by the jury to $20,000, but it appears the jury may have reached its fraud total by adding $20,000 to the contract damages. –4– In a legal-sufficiency review, we must consider all the evidence “in the light

most favorable to the party in whose favor the verdict has been rendered,” and “every

reasonable inference deducible from the evidence is to be indulged in that party’s

favor[.]” Bustamante v. Ponte, 529 S.W.3d 447, 456 (Tex. 2017) (quoting Merrell

Dow Pharms., Inc. v. Havner, 953 S.W.2d 706, 711 (Tex. 1997)). We may sustain a

legal-sufficiency challenge—that is, a no-evidence challenge—only when (1) the

record bears no evidence of a vital fact, (2) the rules of law or of evidence bar the

court from giving weight to the only evidence offered to prove a vital fact, (3) the

evidence offered to prove a vital fact is no more than a mere scintilla, or (4) the

evidence establishes conclusively the opposite of a vital fact. Gunn v. McCoy, 554

S.W.3d 645, 658 (Tex. 2018). When the evidence offered to prove a vital fact is so

weak that it creates no more than a mere surmise or suspicion of its existence, the

evidence is no more than a scintilla and, in legal effect, is no evidence. King Ranch,

Inc. v. Chapman, 118 S.W.3d 742, 751 (Tex. 2003); Kindred v. Con/Chem, Inc., 650

S.W.2d 61, 63 (Tex. 1983).

In a factual-sufficiency review, we set aside a finding only if, after considering

and weighing all the pertinent record evidence, we determine that the credible

evidence supporting the finding is so weak, or so contrary to the overwhelming

weight of all the evidence, that the finding should be set aside and a new trial

ordered. Pool v. Ford Motor Co., 715 S.W.2d 629, 635 (Tex. 1986) (op. on reh’g);

Cain v. Bain, 709 S.W.2d 175, 176 (Tex. 1986) (when party complaining of factual

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Amazon.com Services LLC v. Reginald Grant, Counsel Stack Legal Research, https://law.counselstack.com/opinion/amazoncom-services-llc-v-reginald-grant-texapp-2024.