Approximately $14,980.00 v. State

CourtCourt of Appeals of Texas
DecidedJune 12, 2008
Docket14-07-00164-CV
StatusPublished

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Bluebook
Approximately $14,980.00 v. State, (Tex. Ct. App. 2008).

Opinion

Reversed and Remanded and Majority and Concurring Opinions filed June 12, 2008

Reversed and Remanded and Majority and Concurring Opinions filed June 12, 2008.

In The

Fourteenth Court of Appeals

____________

NO. 14-07-00164-CV

APPROXIMATELY $14,980.00, Appellant

V.

THE STATE OF TEXAS, Appellee

On Appeal from the 125th District Court

Harris County, Texas

Trial Court Cause No. 2006-41188

M A J O R I T Y   O P I N I O N


This is an appeal from a seizure and forfeiture proceeding under Chapter 59 of the Texas Code of Criminal Procedure.[1]  Following a bench trial, the trial court entered a default judgment against appellant Hermes Antonio Rodriguez,[2] and based on deemed admissions ordered that $14,980.00 be forfeited to the State.  In six issues, appellant contends the trial court erred in not permitting him to demonstrate non-receipt of the discovery requests and in admitting the deemed admissions into evidence.  We conclude the trial court erred in deciding, pursuant to a local court rule, not to consider evidence that appellant did not receive service of the requests, and we reverse the judgment of the trial court.

I.  Factual and Procedural Background

On June 30, 2006, the State filed a Notice of Seizure and Intended Forfeiture, stating it had seized contraband property of approximately $14,980.00 from appellant and that the property was subject to forfeiture.  Appellant filed an answer generally denying the allegations and served interrogatories and requests for disclosure on the State.  The State served appellant via certified mail, return receipt requested, with requests for admissions.  The requests were sent to appellant=s attorney=s last known address.  Although the requests did not include a certificate of service, the State included a certificate of written discovery and also filed the discovery certificate with the court.  The record reflects that delivery was attempted on October 21, 2006 and again October 26, 2006.[3]  The envelope containing the requests for admissions was returned to the State bearing the United States Post Office stamp Aunclaimed.@


At trial on February 19, 2007, the State submitted the unanswered requests for admissions into evidence, claiming that due to appellant=s failure to respond, the requests were deemed admitted as a matter of law.  The State also submitted the returned envelope bearing the Aunclaimed@ stamp and the certified mail receipt showing the two failed attempts at service.  Based on the deemed admissions, the State moved for a post-answer default judgment.  Appellant objected, claiming that he had never received the discovery requests.  He also argued that because no certificate of service was included in the requests, the State had failed to comply with Texas Rule of Civil Procedure 21a and therefore could not prove service of notice.  Appellant made an oral motion to have the deemed admissions set aside, but the trial court refused the motion because local court rules require that all motions be filed in writing ten days prior to the hearing or trial.  The court denied appellant=s motion for continuance on the same grounds.  Appellant argued that Rule 21a entitled him to an opportunity to present evidence proving non-receipt of service.  The trial court ultimately disagreed with appellant and refused to consider any evidence of non-receipt of service or to allow him to withdraw the deemed admissions.  The trial court admitted the deemed admissions into evidence and signed a final judgment ordering that the $14,980.00 be forfeited to the State.

In six issues on appeal, appellant contends the trial court erred in (1) deeming the requests for admissions admitted because service was not perfected, (2) refusing to consider evidence rebutting any presumption of service, and (3) finding that the $14,980.00 was contraband because without the deemed admissions, the evidence was legally insufficient.

II.  Standard of Review

The decision to allow or deny the withdrawal of deemed admissions lies within the broad discretion of the trial court.  Steffan v. Steffan, 29 S.W.3d 627, 631 (Tex. App.CHouston [14th Dist.] 2000, pet. denied).  An appellate court should set aside the trial court=s ruling only if, after reviewing the entire record, the trial court clearly abused its discretion by acting without reference to guiding rules or principles, or acted arbitrarily or unreasonably.  Id.  We also review the trial court=s application of local court rules in deciding not to hear a motion rebutting the presumption of service of discovery requests under an abuse of discretion standard.  See Approximately $1,589.00 v. State, 230 S.W.3d 871, 873 (Tex. App.CHouston [14th Dist.] 2007, no pet.) (holding that clear failure to correctly analyze or apply law constitutes an abuse of discretion).


III.  Analysis

Texas Rule of Civil Procedure 198 entitles a litigant to serve requests for admissions on another party.  See Tex. R. Civ. P. 198.1.  Failure to timely respond results in each request being deemed admitted by operation of law.  See Tex. R. Civ. P. 198.2(c).  Rule 198.3 permits withdrawal of the deemed admissions if the party shows good cause for the withdrawal, the court finds that the parties relying on the deemed admissions will not be unduly prejudiced, and the court finds that the presentation of the merits of the action will be subserved by permitting the withdrawal.  Tex. R. Civ. P.

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