Angela Harvey v. Olshan Foundation Repair Company of Houston LLC and Doug Joslyn

CourtCourt of Appeals of Texas
DecidedDecember 30, 2020
Docket09-18-00467-CV
StatusPublished

This text of Angela Harvey v. Olshan Foundation Repair Company of Houston LLC and Doug Joslyn (Angela Harvey v. Olshan Foundation Repair Company of Houston LLC and Doug Joslyn) 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
Angela Harvey v. Olshan Foundation Repair Company of Houston LLC and Doug Joslyn, (Tex. Ct. App. 2020).

Opinion

In The

Court of Appeals

Ninth District of Texas at Beaumont

__________________

NO. 09-18-00467-CV __________________

ANGELA HARVEY, Appellant

V.

OLSHAN FOUNDATION REPAIR COMPANY OF HOUSTON LLC, AND DOUG JOSLYN, Appellees

__________________________________________________________________

On Appeal from the 284th Judicial District Court Montgomery County, Texas Trial Cause No. 15-09-10110-CV __________________________________________________________________

MEMORANDUM OPINION

Angela Harvey, the beneficiary of a warranty sold to her by Olshan

Foundation Repair Company of Houston LLC, appeals from the trial court’s ruling

granting the motions for summary judgment of the defendants, Olshan and Doug

Joslyn. Harvey sued Joslyn because he is one of the previous individuals who owned

the home, but he did not own the home when Harvey acquired it in 2013.

1 Harvey filed a brief raising two issues for our review. In Harvey’s first issue,

she argues the judgment should be reversed because while she asked the trial court

for written findings to support its ruling, the court failed to comply. In Harvey’s

second issue, she contends that, given the evidence she produced with the response

she filed to Olshan’s motion, genuine issues of material fact remain to be decided on

the elements on five of her claims, her claims alleging Olshan breached the express

warranty it made to her to repair the foundation, breached the implied warranty of

good and workmanlike repairs based on the work it did for one of the earlier

homeowner s of the home, breached its agreement with her to repair the foundation

properly, committed fraud, and violated the DTPA.

We conclude that Harvey’s argument suggesting the trial court erred in failing

to honor her request for written findings is without merit. As that’s the sole error

Harvey assigns to the trial court’s ruling on Joslyn’s motion, the take-nothing

judgment the trial court rendered against Joslyn is affirmed. Turning to Harvey’s

remaining issue, which assails the trial court’s ruling on Olshan’s motion, we

conclude the ruling should be affirmed on two of Harvey’s claims, her claim alleging

Olshan breached its implied warranty of good and workmanlike repair and her claim

alleging Olshan committed fraud. That said, we also conclude the record does not

support the trial court’s remaining rulings on the claims Harvey filed against Olshan

2 alleging Olshan breached the terms of the express warranty it made to her covering

its work, breached its contract to repair it work, and violated the DTPA.

Background

The home involved in the suit is in Montgomery County, Texas. Harvey

bought the home in 2013 from Sharon and James Thompson. Before they sold the

home to Harvey, but on a date the record fails to show, the Thompsons hired Olshan

to repair the foundation supporting their home. The evidence does not show when

Olshan completed the repairs it performed for Thompsons, nor does it contain the

written agreement between the Thompsons and Olshan, which would have provided

information relevant to the scope of the work Olshan performed. In any event, the

dispute in this case hinged on whether the evidence the parties provided in the trial

court shows that Olshan worked on the foundation in the area that Harvey claimed

the foundation was in need of repair, an area the parties referred to as the back

addition to Harvey’s home. We will refer to the area Harvey sued Olshan for refusing

to repair as the area in dispute.

When Harvey was negotiating her purchase of the home, the Thompsons gave

her a written statement, which discloses that the foundation had been repaired. A

copy of the disclosure statement the Thompsons gave Harvey in connection with the

transaction that resulted in the home’s sale is among the summary-judgment

evidence the parties provided in the court below. While the Thompsons’ disclosure

3 reveals they were aware that work had been done on the foundation, it does not show

who did the work, when it was done, or explain the scope of the repairs that at some

point were completed to the home.

Before closing on the home, Harvey hired a home inspector to inspect the

home. The inspection service did so and provided her with a report. In the report,

which is dated July 2013, the inspection services reported that signs of movement

were visible around the foundation, at the front entry and above the half bath. The

report recommends that before purchasing the property, Harvey should hire a

“qualified structural engineer or foundation expert . . . to determine if permanent

repairs are required.” The report is among the summary-judgment exhibits Olshan

filed to support its hybrid motion.

After Harvey received the report, she hired Texans Foundation Repair to

inspect and evaluate the foundation. After Texans Foundation did so, it

recommended the foundation needed repairs and gave Harvey a bid to stabilize the

foundation “at [a] feasible level[,]” which Texans Foundation proposed to

accomplish by installing twenty-five additional piers under the existing foundation.

The bid is among the summary-judgment exhibits the trial court considered in

deciding Olshan’s motion.

Olshan took Harvey’s deposition during discovery. Olshan also relied on

Harvey’s deposition in its motion for summary judgment. In her deposition, Harvey

4 testified that, in July 2013, she learned from Texans Foundation that the home’s

foundation had been repaired. She also testified that she learned the foundation

needed to be repaired in the area in dispute. While acknowledging that Texans

Foundation had given her a bid, Harvey explained she chose not to hire the company

to perform any repairs because she decided to rely on the lifetime warranty Olshan

sold her guaranteeing to repair the work it had done on the foundation in the past.

Several months after buying the house, and after paying Olshan fee to transfer

the warranty Olshan gave the Thompsons on its work to her, Harvey asked Olshan

to inspect the foundation supporting what was, at that point, her home. In its motion

for summary judgment, Olshan alleged it “honored its warranty, [by] adjusting

pilings it had previously installed.” 1 Olshan also alleged that it never worked on the

“back addition” to the home, that is, the area in dispute. And Olshan’s motion alleges

that Harvey could produce no evidence to show that Olshan ever worked on the

foundation in the area in dispute. In its motion, Olshan acknowledged that it

1 Olshan and Harvey did not provide the trial court with any paperwork on Olshan’s work or the paperwork associated with Olshan’s lifetime warranty and Olshan’s agreement transferring the warranty to Harvey. Yet, Olshan has never disputed that Harvey acquired the warranty on the foundation for the work it did there. Thus, the dispute concerns whether the lifetime warranty applies to the area in dispute. For instance, Olshan’s motion for summary judgment alleges that its warranty “only covers the work” Olshan did on the foundation, “not new issues that might arise in other portions of [the] home’s foundation.” And while Olshan alleged it never worked in the area in dispute, it did not produce corporate records or testimony from its employees explaining what parts of the foundation were included in the repairs it was paid to perform by the Thompsons.

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Angela Harvey v. Olshan Foundation Repair Company of Houston LLC and Doug Joslyn, Counsel Stack Legal Research, https://law.counselstack.com/opinion/angela-harvey-v-olshan-foundation-repair-company-of-houston-llc-and-doug-texapp-2020.