Banquete Independent School District v. The Alliance for Community Solutions, Ltd.

CourtDistrict Court, S.D. Texas
DecidedMarch 31, 2025
Docket2:22-cv-00094
StatusUnknown

This text of Banquete Independent School District v. The Alliance for Community Solutions, Ltd. (Banquete Independent School District v. The Alliance for Community Solutions, Ltd.) is published on Counsel Stack Legal Research, covering District Court, S.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Banquete Independent School District v. The Alliance for Community Solutions, Ltd., (S.D. Tex. 2025).

Opinion

□ Southern District of Texas ENTERED March 31, 2025 UNITED STATES DISTRICT COURT Nathan Ochsner. Clerk SOUTHERN DISTRICT OF TEXAS CORPUS CHRISTI DIVISION

BANQUETE INDEPENDENT SCHOOL § DISTRICT, § § Plaintiff, § § V. § CIVIL ACTION NO. 2:22-CV-00094 § THE ALLIANCE FOR COMMUNITY § SOLUTIONS, LTD., § § Defendant. §

ORDER ADOPTING MEMORANDUM AND RECOMMENDATION Before the Court is Magistrate Judge Jason B. Libby’s Memorandum and Recommendation (“M&R”). (D.E. 60). The M&R recommends that the Court: (1) Grant Defendant’s motion for summary judgment on Plaintiffs negligence and negligent misrepresentation claims; (2) Deny Defendant’s motion for summary judgment on Plaintiffs fraud claim; (3) Deny Defendant’s motion for summary judgment on Plaintiffs remedies of rescission, constructive trust, punitive damages, and attorney fees; and (4) Deny Defendant’s request for declaratory judgment holding that Texas Education Code § 44, rather than Texas Government Code § 2269, governs the Interlocal Agreement. (D.E. 60, p. 10, 14, 16, 19). The parties both filed written objections. (D.E. 63; D.E. 64). Plaintiff filed a response to Defendant’s objections. (D.E. 65). After review, the Court OVERRULES Plaintiff's objections, (D.E. 63), OVERRULES in part and SUSTAINS in part Defendant’s objections, (D.E. 64), and ADOPTS in part the M&R, (D.E. 60). Accordingly, the Court GRANTS Defendant’s motions for partial summary judgment. (D.E. 29; D.E. 48). 1/12

I. Law When a party objects to the findings and recommendations of a magistrate judge, the district judge “shall make a de novo determination of those portions of the report or specified proposed findings or recommendations to which objection is made.” 28 U.S.C. § 636(b)(1)(C). A party “must point out with particularity” any alleged errors in the magistrate judge’s analysis. Pelko v. Perales, No. 2:23-CV-00339, 2024 WL 1972896, at *1 (S.D. Tex. May 3, 2024) (Ramos, J.). Objections that merely re-urge arguments contained in the original briefing are not proper and will not be considered. See Edmond v. Collins, 8 F.3d 290, 293 n.7 (Sth Cir. 1993) (declining to consider an objection supported only by a copy of the brief used previously in the original petition); see also Smith v. Collins, 964 F.2d 483, 485 (5th Cir. 1992) (declining to review de novo where defendant’s objection “raised no factual objections to the recommendation but merely reurged the legal arguments he raised in his original petition”). Moreover, “[f]rivolous, conclusive or general objections need not be considered by the district court.” Nettles v. Wainwright, 677 F.2d 404, 410 n.8 (5th Cir. 1982) (en banc), overruled on other grounds by Douglass v. United Servs. Auto. Ass’n, 79 F.3d 1415, 1416 (Sth Cir. 1996) (en banc), superseded by statute on other grounds, 28 U.S.C. § 636(b)(1). As to any portion for which no objection is filed, a district court reviews for clearly erroneous factual findings and conclusions of law. United States v. Wilson, 864 F.2d 1219, 1221 (Sth Cir. 1989) (per curiam). II. Objections to the M&R A. Plaintiff's objection to application of the economic loss rule Plaintiff objects to the M&R’s recommendation that the Court grant Defendant’s motion for summary judgment on Plaintiff's negligence claim and negligent misrepresentation claim because the economic loss rule bars both claims. (D.E. 63, p. 1-2). Plaintiff contends that because

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it withdrew its breach of contract claim from suit, “all claims ... and all harm associated with [Plaintiff's] negligence claim [are] outside of’ and “independent from any contractual undertaking.” (D.E. 42, p. 10; D.E. 63, p. 2). Therefore, Plaintiff argues, the economic loss rule cannot bar its negligence and negligent misrepresentation claims. (D.E. 42, p. 10; D.E. 63, p. 2). Plaintiff further claims “actual damage” to its property—namely, wet floors—as evidence of injury that exceeds purely economic loss. (D.E. 42, p. 11; D.E. 63, p. 2). Plaintiff previously presented these arguments! in its response to Defendant’s motion for summary judgment. Compare (D.E. 42, p. 10-11), with (D.E. 63, p. 2). The arguments amount to mostly conclusory assertions that “a genuine issue of material fact exists” merely because “Plaintiff has demonstrated that all .. . elements . . . have been met.” See (D.E. 63, p. 2). As arguments that only reintroduce those contained in the original briefing are improper, and conclusory statements need not be considered, the Court OVERRULES Plaintiff's objection. See

' The Court agrees with the M&R’s conclusion of Plaintiff's attempt to circumvent the economic loss rule by alleging property damage. (D.E. 60, p. 8-10). The “economic loss rule generally prevents recovery in tort for purely economic damage unaccompanied by injury to persons or property.” Golden Spread Elec. Coop., Inc. vy. Emerson Process Mgmt. Power & Water Sols., Inc., 954 F.3d 804, 808 (Sth Cir. 2020) (first citing LAN/STV v. Martin K. Eby Const. Co., 435 S.W.3d 234, 235 (Tex. 2014); then citing Sharyland Water Supply Corp. v. City of Alton, 354 S.W.3d 407, 418 (Tex. 2011); and then citing Am. Eagle Ins. Co. v. United Techs. Corp., 48 F.3d 142, 144 (5th Cir.), on reh’g, 51 F.3d 468 (Sth Cir. 1995)). Under Texas law, floor damage resulting from excessive water can be property damage beyond economic loss. See, e.g., Chapman Custom Homes, Inc. v. Dallas Plumbing Co., 445 S.W.3d 716, 718-19 (Tex. 2014) (per curiam) (concluding economic loss rule did not bar recovery for water damage to property). However, Plaintiff did not claim any property damage until its opposition to summary judgment. See (D.E. 40, p. 7-8) (no claim of property damage); (D.E. 42, p. 11) (first claim of property damage); (D.E. 60, p. 8-9, n.3) (noting Plaintiff did not supplement information regarding floor damage until summary judgment). The M&R referenced Plaintiff's lack of evidence as the basis of its recommendation. (D.E. 60, p. 9). However, Plaintiff’s property-damage claim does not suffice due to Plaintiffs failure to plead it. This failure is why Plaintiff cannot avoid the economic loss rule: Plaintiff has no claim for property damage properly before the Court. In other words, the lack of evidence noted by the M&R serves to demonstrate the problem that results from a party’s failure to plead a claim. “A claim which is not raised in the complaint but, rather, is raised only in response to a motion for summary judgment is not properly before the court.” Cutrera v. Bd. of Sup ’rs of Louisiana State Univ., 429 F.3d 108, 113 (5th Cir. 2005) (citing Fisher v. Metro. Life Ins. Co., 895 F.2d 1073, 1078 (Sth Cir. 1990)). Accordingly, the Court does not consider Plaintiff's property-damage claim. 3/12

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Bluebook (online)
Banquete Independent School District v. The Alliance for Community Solutions, Ltd., Counsel Stack Legal Research, https://law.counselstack.com/opinion/banquete-independent-school-district-v-the-alliance-for-community-txsd-2025.