Betty Rathbun Ligon v. Judith D. Casey

CourtCourt of Appeals of Texas
DecidedJuly 27, 2023
Docket01-22-00247-CV
StatusPublished

This text of Betty Rathbun Ligon v. Judith D. Casey (Betty Rathbun Ligon v. Judith D. Casey) 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
Betty Rathbun Ligon v. Judith D. Casey, (Tex. Ct. App. 2023).

Opinion

Opinion issued July 27, 2023

In The

Court of Appeals For The

First District of Texas ——————————— NO. 01-22-00247-CV ——————————— BETTY RATHBUN LIGON, Appellant/Cross-Appellee V. JUDITH D. CASEY, Appellee/Cross-Appellant

On Appeal from the 55th District Court Harris County, Texas Trial Court Case No. 2014-67737

MEMORANDUM OPINION

Appellant/cross-appellee, Betty Rathbun Ligon, challenges the trial court’s

judgment, entered after a jury trial, in the suit of appellee/cross-appellant, Judith D.

Casey, against Ligon for breach of contract, breach of partnership agreement, breach

of duty of care, quantum meruit, promissory estoppel, breach of fiduciary duty, fraud, fraud by nondisclosure, and money had and received. In three issues, Ligon

contends that the trial court erred in concluding that the statute of limitations did not

bar Casey’s damages claims.

In her sole issue on cross-appeal, Casey contends that the trial court erred in

denying her motion to disregard certain jury findings.

We affirm.

Background

Casey filed suit against Ligon on November 19, 2014. In her fourth amended

petition, Casey alleged that “[f]rom around July of 2005 to August of 2013, [she]

and Ligon were partners” in a company called MedPerm Permanent Placement, Inc.,

doing business as Therapy Consultants (“MedPerm”).1 According to Casey,

MedPerm was a “medical placement firm” that recruited and placed speech

therapists with various school districts. Because of school scheduling and contract

needs, Casey and Ligon performed “[e]ssentially all” of their work in the spring and

summer prior to the school year in which the speech pathologists began working

under their contracts. Casey alleged that she and Ligon would “make their profits

based on what they billed to the school districts for the hours worked” by the speech

therapists. They “agreed to” a fifty-fifty “split” of MedPerm’s net profits, which

1 MedPerm was a defendant in Casey’s suit but Casey’s claims against MedPerm were dismissed before trial, and it is not a party to this appeal. 2 “were calculated by adding up the amount billed to the school districts for each

therapist they placed and subtracting business expenses.”

In August 2013, “without Casey’s knowledge,” Ligon sold MedPerm under a

“Stock Purchase Agreement” to Robert and Rebecca Strobel (collectively, “the

Strobels”). Before Ligon and the Strobels entered into the Stock Purchase

Agreement, Ligon informed the Strobels “that her agreement with Casey was that

most everything was split down the middle.” (Internal quotations omitted.) The

Strobels and Ligon then “spent two months” negotiating the sale to address the

Strobels’ “insistence on protection” from any possible claims by Casey “after the

sale [of MedPerm] became final.”

Casey further alleged that Ligon refused the Strobels’ request to obtain a

release from Casey or meet with her. When the Strobels were about to “walk[] away

from the sale,” Ligon offered to “warrant that Casey [wa]s not a partner and [wa]s

not entitled to a percentage of” MedPerm’s profits and “indemnify the Strobels if

the warranty [wa]s breached.” According to an email written by Ligon to the

Strobels, Ligon believed that Casey would not “pursu[e] any partnership claims”

because Casey “was 72 years old” and had “an ill husband.”

The Strobels accepted Ligon’s warranty and indemnification and paid Ligon

$875,000.00 for MedPerm under the Stock Purchase Agreement. Ligon also

received “the cash in MedPerm’s accounts and the accounts receivable.” According

3 to Casey, based on her partnership with Ligon, “as established through the[ir] course

of dealings” for the previous eight years, she was “entitled to [fifty percent] of the

proceeds from the sale, the cash, and the accounts receivable.”

Further, Casey alleged that “[a]fter the sale” of MedPerm to the Strobels,

MedPerm earned “at least $2,178,221 in revenue” during the “2013-2014 school

year based on contracts secured by Casey”2 in spring 2013. Yet, “MedPerm did not

pay Casey” the share of “profits [that] she was entitled to.”

Casey brought claims against Ligon for breach of common-law partnership

and statutory partnership under the Texas Business Organizations Code. She alleged

that she and Ligon had agreed that both “would work together in MedPerm and

would split the profits equally.” Further, they “had a community of interest in

MedPerm” and “a mutual right to manage MedPerm.” But Ligon “breached the

partnership agreement by selling MedPerm without Casey’s consent and retaining

Casey’s agreed share of [the] profits, cash[,] and accounts receivable [that] Ligon

obtained through th[e] sale.” And because “Ligon’s calculation of anticipated

expenses of MedPerm were not always accurate,” Casey paid “more into MedPerm’s

operating account than was necessary.” Because of Ligon’s accounting errors,

Casey did not receive her full share of net profits.

2 See TEX. BUS. ORGS. CODE ANN. § 152.052. 4 Casey also brought a claim against Ligon for breach of her fiduciary duty and

a statutorily imposed duty of care3 because Ligon “misrepresented the amount due

to [MedPerm’s] operating account each month”; “sold MedPerm without [her]

permission”; “wound up the partnership without notifying [her]”; and “failed to

split” MedPerm’s “profits, . . . cash, and . . . accounts receivable” with her “after the

sale.” And Casey asserted a claim for fraud against Ligon, alleging that Ligon had

falsely “represented to Casey that they were partners” in MedPerm and Casey was

entitled to receive fifty percent “of the net profits.” Further, during the eight years

that Ligon and Casey had worked together, Ligon had falsely “represented to Casey”

that she was receiving fifty percent of MedPerm’s net profits. According to Casey,

these misrepresentations were material because MedPerm “was Casey’s livelihood

for eight years, and she worked very hard toward growing MedPerm in order to

receive her share of the profits.” And Casey relied on Ligon’s misrepresentations

“by contributing to the business in the [s]pring and [s]ummer of 2013 to secure

contracts on behalf of MedPerm.”

Casey further alleged that Ligon’s breach of their partnership, breaches of her

duties of care and loyalty, and fraud “caused injury to Casey of between at least

3 See id. § 152.206. 5 $576,685.00 and up to $1,000,000.00.” Casey also requested attorney’s fees,

pre-judgment and post-judgment interest, and court costs.

Ligon answered, generally denying the allegations in Casey’s petition. She

also asserted that she and Casey had no partnership agreement, and Casey’s claims

were barred by the statute of limitations and the statute of frauds. And Ligon filed

a counterclaim against Casey.

In her second amended original counterclaim, Ligon alleged that beginning in

April 2005, she “was in the business of placing speech therapists . . . with various

school districts.” The speech therapists “were employees of Ligon,” and the school

districts paid her a “flat fee for each therapist [who was] placed with them.”

Ligon operated her business “under the assumed name of Therapy

Consultants.” She “hired Casey as an independent contractor . . . to assist with

Ligon’s work and business.” According to Ligon, “Casey’s duties required her to

identify and recruit” speech therapists and “obtain the necessary paperwork,”

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