Bank of America, N.A. v. Helen Hubler

CourtCourt of Appeals of Texas
DecidedDecember 6, 2006
Docket10-05-00404-CV
StatusPublished

This text of Bank of America, N.A. v. Helen Hubler (Bank of America, N.A. v. Helen Hubler) 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
Bank of America, N.A. v. Helen Hubler, (Tex. Ct. App. 2006).

Opinion

IN THE

TENTH COURT OF APPEALS

 

No. 10-05-00404-CV

Bank of America, N.A.,

                                                                      Appellant

 v.

Helen Hubler,

                                                                      Appellee


From the 220th District Court

Bosque County, Texas

Trial Court No. 04-09-213-04BCCV

Opinion


          Helen Hubler filed suit against Bank of America, N.A. after the Bank withdrew funds from her account to pay a check for which the Bank had previously stopped payment.  The court rendered judgment in Hubler’s favor.  On appeal, the Bank contends: (1) there is no evidence or factually insufficient evidence that it breached the parties’ deposit agreement; (2) there is no evidence or factually insufficient evidence of contractual modification; (3) Hubler’s tort claims are barred because they sound in contract only; (4) there is no evidence or factually insufficient evidence of causation; (5) there is no evidence or factually insufficient evidence that Hubler’s reliance was justifiable; and (6) Hubler failed to mitigate her damages.  In one cross-point, Hubler challenges the court’s failure to award attorney’s fees.  We will affirm in part and reverse and remand in part.

BACKGROUND

          Hubler hired Wade Morrow to construct a barn for $47,500.  Morrow requested the money in advance, which Hubler paid with a check.  Both Hubler and Morrow maintained accounts at Bank of America.  Karen Tse, a Bank representative, subsequently contacted Hubler to inquire about the check because Morrow’s account had previously exhibited little activity.  Hubler acknowledged writing the check.  After continued conversation with Tse, Hubler grew concerned and requested a stop-payment.  Tse accepted the request.  That same day, another Bank representative initially declined to stop-payment.  After speaking with Tse, the representative agreed to honor the request.  Hubler received a stop-payment notice, and the funds were returned to her account.

          A few days later, Hubler received a call informing her that the Bank could not stop-payment and the funds would again be withdrawn from her account.  The Bank also sent a letter explaining that it was too late to stop payment because Hubler’s request came after Morrow had already negotiated the check.  Morrow then withdrew all the funds from his account.

Standards of Review

A no evidence issue requires consideration of “whether the evidence at trial would enable reasonable and fair-minded people to reach the verdict under review.”  City of Keller v. Wilson, 168 S.W.3d 802, 827 (Tex. 2005).  We “must credit favorable evidence if reasonable jurors could, and disregard contrary evidence unless reasonable jurors could not.”  Id.  This standard also applies to a court’s findings made in a bench trial.  See Kilpatrick v. McKenzie, No. 14-04-00986-CV, 2006 WL 1675421, at *2 (Tex. App.—Houston [14th Dist.] June 20, 2006, no pet.); see also Ludwig v. Encore Med., L.P., 191 S.W.3d 285, 294 (Tex. App.—Austin 2006, pet. denied); Catalina v. Blasdel, 881 S.W.2d 295, 297 (Tex. 1994).

A factual sufficiency challenge to issues on which the appellant did not bear the burden of proof requires us to “consider and weigh all of the evidence.”  Checker Bag Co. v. Washington, 27 S.W.3d 625, 633 (Tex. App.—Waco 2000, pet. denied).  We will reverse the “verdict only if it is so contrary to the overwhelming weight of the evidence that the verdict is clearly wrong and unjust.”  IdOn issues where the appellant “bears the burden of proof,” we will reverse only if, “considering all the evidence, the finding is so contrary to the great weight and preponderance of the evidence as to be manifestly unjust.”  Id.

BREACH OF CONTRACT

          In its first issue, the Bank contends there is no evidence or factually insufficient evidence to support the finding that the Bank breached its contract with Hubler.  The contract provides:

For example, if you give us a stop-payment order after our cutoff time and the item you want to stop was presented for payment the previous business day, your order comes too late to stop-payment on the item.[1]

          …

We may debit your account for a check or other item drawn on your account either on the day it is presented to us for payment, by electronic or other means, or on the day we receive notice that the item has been deposited for collection at another financial institution—whichever is earlier. 

The Bank relies on these provisions for the proposition that it cannot be held liable for breach because Hubler’s stop-payment request came after presentment and after the Bank’s cutoff time.[2]     

It is undisputed that Hubler’s stop-payment request came too late under the terms of the deposit agreement.  However, the facts presented differ from those contemplated by the contract.  First, despite the contractual language, the Bank stopped payment and returned the funds to Hubler’s account.  Second, after stopping payment and crediting Hubler’s account, the Bank reversed the transaction.  The court found this conduct to constitute a breach of the deposit agreement:

Bank of America, N.A. breached its agreement when, on December 24, 2003, without authorization from Plaintiff, it debited the amount of $47,500.00 from Plaintiff’s account, thus depriving Plaintiff the rightful use of said funds.

“When a customer deposits funds with a bank, the bank impliedly agrees to disburse those funds only in accordance with the depositor’s instructions.”  FNFS, Ltd. v. Sec. State Bank & Trust

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Bank of America, N.A. v. Helen Hubler, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bank-of-america-na-v-helen-hubler-texapp-2006.