ATC Healthcare Services, Inc. v. New Century Financial, Inc.

CourtCourt of Appeals of Texas
DecidedJuly 14, 2011
Docket01-10-00940-CV
StatusPublished

This text of ATC Healthcare Services, Inc. v. New Century Financial, Inc. (ATC Healthcare Services, Inc. v. New Century Financial, Inc.) 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
ATC Healthcare Services, Inc. v. New Century Financial, Inc., (Tex. Ct. App. 2011).

Opinion

Opinion issued July 14, 2011.

In The

Court of Appeals

For The

First District of Texas

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NO. 01-10-00940-CV

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ATC Healthcare Services, Inc., Appellant

V.

New Century Financial, Inc., Appellee

On Appeal from the 152nd District Court

Harris County, Texas

Trial Court Case No. 2007-38981

MEMORANDUM OPINION

This appeal involves New Century Financial, Inc.’s enforcement of its security interest in certain collateral of Chicago Nurses, Inc., a medical staffing agency that operated in the state of Georgia that has since dissolved.  Invoking its rights under a past franchise agreement with Chicago Nurses, ATC Healthcare Services, Inc. (ATC) challenges the trial court’s judgment enforcing New Century’s security interest in the collateral and dismissing ATC’s counterclaims against New Century for tortious interference with contract.  ATC further contends that the trial court erred in adwarding attorney’s fees.  We reverse the award of attorney’s fees and remand that portion of the proceeding for a new hearing.  We affirm the remainder of the judgment.

Background

New Century is a factoring company, or factor, that purchases accounts receivable from businesses to secure business operating loans.  Under a factoring agreement, the factor purchases a client’s billing invoices at a discount in exchange for a security interest in the receivables owed by third parties in payment of these invoices.  Through this transaction, the client gains short-term working capital funds.  The factor pays a discounted amount for the invoices and manages the receivables and collections.  On payment, the factor remits a portion of the payment to the factoring client, retaining the remainder for service fees.

New Century entered into a factoring agreement with Chicago Nurses in September 2006.  At the time, Chicago Nurses already had a factoring line with Advance Financial Corporation with a credit advance of $200,000.  As part of the agreement, New Century agreed to discharge the balance that Chicago Nurses owed to Advance.  In exchange, New Century acquired the right to collect Chicago Nurse’s accounts with Chestatec Medical Center, Grady Health System, Emory Health Care, and Northeast Georgia Health System (the account debtors).  Pertinent to the parties’ dispute, the factoring agreement provides:

SECURITY INTEREST.  As a further inducement for [New Century] to enter into this agreement, [Chicago Nurses] hereby grants to [New Century], as collateral and security for the performance of any obligations hereunder, a Security Interest, under the Illinois and Georgia Uniform Commercial Codes, in all of [Chicago Nurse’s] presently owned or hereafter acquired accounts, accounts receivable, contract rights, chattel paper, documents, instruments, money deposit accounts (including the reserve account and any portion of the Maximum Company Discount not rebated to [Chicago Nurses] hereunder), general intangibles, insurance policies, all goods, equipment and inventory.  [Chicago Nurses] shall not sell, transfer, or otherwise convey or dispose of any of said property except finished inventory held for sale and sold in [Chicago Nurse’s] usual course of business.

Chicago Nurses and Advance informed New Century that the balanced owed on the accounts receivables transferred from Advance was due and outstanding.  New Century relied on that representation and did not independently verify the status of these accounts or whether the receivables were collectible.  New Century then perfected its interest in Chicago Nurse’s collateral by filing UCC financing statements in Illinois and Georgia.  The filing statements covered:

All presently existing or hereafter arising, now owned or hereafter acquired, accounts, accounts receivable, contract rights, chattel paper, documents, instruments, money deposit accounts, all other rights to payment, general intangibles, goods, equipment, and inventory.  [Chicago Nurses] is not authorized to sell, transfer, or otherwise convey or dispose of any said property except finished inventory held for sale and sold in the normal course of business.

Also pursuant to the factoring agreement, New Century informed the account debtors of New Century’s right to payment.  The notice provided that “[t]his notice and instruction remains in full force and effect until you are notified by both the undersigned and New Century Financial, Inc. in writing to the contrary.”  Within the next few weeks, the account debtors signed and acknowledged receipt of New Century’s notice directing that all payments of future amounts be made payable to Chicago Nurses and New Century. 

In November 2006, New Century stopped receiving payments on some of the invoices subject to the factoring agreement.  New Century learned that approximately $90,000 owed under the accounts was uncollectible, but determined that it could remedy this shortfall by enforcing its interest in the account debtors’ future accounts receivable.

A couple of weeks later, on December 5, 2006, Chicago Nurses and ATC entered into a franchise agreement.  ATC did not search for account liens before entering into the franchise agreement, and Chicago Nurses did not seek authorization for the discharge of debt or transfer of collateral subject to New Century’s security interest, as it had with Advance.  The franchise agreement included unusually favorable terms for Chicago Nurses.  ATC waived the franchise fee and instead paid Chicago Nurses $70,000 for the franchise, and agreed to pay 70% of the gross margin as a royalty payment instead of the 55% Chicago Nurses had paid to each of its other franchisees.  The franchise agreement also required Chicago Nurses to stop billing its clients in its own name and to direct its clients to issue all payments in ATC’s name. 

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ATC Healthcare Services, Inc. v. New Century Financial, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/atc-healthcare-services-inc-v-new-century-financia-texapp-2011.