Bill Carey and Chantal Carey, Individually and as Trustee for the Smith Moore Williams Historical Trust v. Mosser Law PLLC

CourtCourt of Appeals of Texas
DecidedJuly 31, 2024
Docket05-23-00411-CV
StatusPublished

This text of Bill Carey and Chantal Carey, Individually and as Trustee for the Smith Moore Williams Historical Trust v. Mosser Law PLLC (Bill Carey and Chantal Carey, Individually and as Trustee for the Smith Moore Williams Historical Trust v. Mosser Law PLLC) 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.

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Bill Carey and Chantal Carey, Individually and as Trustee for the Smith Moore Williams Historical Trust v. Mosser Law PLLC, (Tex. Ct. App. 2024).

Opinion

AFFIRMED and Opinion Filed July 31, 2024

S In The Court of Appeals Fifth District of Texas at Dallas No. 05-23-00411-CV

BILL CAREY AND CHANTAL CAREY, INDIVIDUALLY AND AS TRUSTEE FOR THE SMITH MOORE WILLIAMS HISTORICAL TRUST, Appellants V. MOSSER LAW PLLC, Appellee

On Appeal from the 429th Judicial District Court Collin County, Texas Trial Court Cause No. 429-02116-2021

MEMORANDUM OPINION Before Justices Garcia, Breedlove, and Kennedy Opinion by Justice Breedlove This is an appeal of the trial court’s dismissal with prejudice of appellants Bill

and Chantal Carey’s1 claims against appellee Mosser Law PLLC following the

sustaining of special exceptions. The Careys argue that the trial judge erred by

dismissing their claims with prejudice because their pleadings provided fair notice

and they made a good faith effort to amend their pleadings to comply with the court’s

1 Bill and Chantal Carey brought this suit both individually and as trustees for the Smith Moore Williams Historical Trust. However, for simplicity, we refer to them as “the Careys.” order. We conclude that the trial court did not err in, first, requiring the Careys to

replead in accordance with the defects identified in its order and, second, in

dismissing the Careys’ claims after they failed to correct those defects. Accordingly,

we affirm the trial court’s judgment.

BACKGROUND

Mosser Law was hired to represent the Careys in a lawsuit brought against

them by the City of Bonham, Texas. After successfully defending the suit, Mosser

Law brought suit on a sworn account against the Careys in April 2021 for the

attorney’s fees the Careys incurred for services rendered in representing them in the

City of Bonham lawsuit.

The Careys filed an Original Answer and Counter-Claims alleging breach of

fiduciary duty, fraud, violations of the Deceptive Trade Practices Act, and

affirmative defenses including failure of consideration, fraud, estoppel, and

illegality. On December 6, 2022, Mosser Law filed 19 special exceptions to the

Careys’ affirmative defenses, damages allegations, and the breach of fiduciary duty

counterclaim.

On February 6, 2023, the trial court sustained all but one of Mosser Law’s

special exceptions.2 The trial court ordered the Careys to replead by February 27,

2 The trial court only denied special exception 16, Mosser Law’s request for the trial court to require each of the named defendants to file separate affidavits. –2– 2023 and warned that a failure to cure would result in the court striking the defective

paragraphs.

On February 27, 2023, the Careys filed their First Amended Original Answer

and Counter-Claims. The next day, Mosser Law moved to strike all of the Careys’

pleadings that were not cured of their defects and asked the court to grant attorney’s

fees and damages. The same day, Mosser Law also filed a separate motion to strike

and motion for sanctions for failure to serve the filed documents according to Texas

Rule of Civil Procedure 21a(a)(1). In the second motion, Mosser Law re-alleged its

arguments from its prior motion to strike and added arguments to support its request

for sanctions against the Careys’ counsel, James Bo Brown, and for attorney’s fees

and damages.

By order dated March 6, 2023, the trial court struck paragraphs 4–9 and 19

from the Careys’ Original Answer and Counter-Claims, granted Mosser Law its

attorney’s fees, granted sanctions against Brown, and also dismissed the Careys’

Original Answer and Counter-Claims with Prejudice.3

The Careys filed a motion for reconsideration on March 13, 2023. Two days

later, and without leave of court, the Careys filed their Second Amended Original

Answer and Counter-Claims.

3 It is unclear why the trial court referred to the “Original Answer and Counter-Claims” when the “Amended Answer and Counter-Claims" was the live pleading before the court at the time it issued its order. –3– On March 16, 2023, Mosser Law again moved to strike the Careys’ pleadings,

alleging that the Second Amended Answer and Counter-Claims repleads facts that

were struck by the trial court and re-urging the arguments made in its prior motions

to strike. In this new motion, however, in addition to asking the court to strike the

defective paragraphs in the Careys’ Second Amended Answer and Counter-Claims,

Mosser Law asked the court to strike the Careys’ Second Amended Answer in its

entirety, dismiss the case with prejudice, and award attorney’s fees and damages to

Mosser Law.

On April 13, 2023, the trial court signed an Amended Order on Plaintiff’s

Motion to Strike Defendants’ Pleadings and Sanctions. The order again struck

paragraphs 4–9 and 19, struck the amount of damages sought by the Careys, granted

Mosser Law its attorney’s fees, and ordered sanctions against the Careys. The trial

court also dismissed the Carey’s Original Answer and Counter-Claims with

prejudice.4

Later the same day, the trial court submitted a Supplemental Final Judgment.

The Supplemental Final Judgment included the following:

On 6 April 2023, the Court held a hearing for Plaintiff’s Motion to Strike Defendants’ Second Amended Original Answer and Counterclaims and for Defendants’ Motion to reconsider the Court’s 6 March 2023 Order striking Defendants’ Pleadings. The Court orally GRANTED Plaintiff’s request to Strike Defendants’ Second Amended

4 It is unclear why the trial court again directed its order to the Original Answer and Counter-Claims instead of the timely-filed Amended Answer and Counter-Claims, or, alternatively, the untimely filed Second Amended Answer and Counter-Claims. –4– Original Answer and Counterclaims and DENIED Defendants’ Motion to Reconsider. Plaintiff has attached its attorney’s fees declaration and evidence for the above numbered and captioned lawsuit as an unsworn declaration signed by James C. Mosser, Attorney in Charge.

All matters in controversy, legal and factual, were submitted to the Court for its determination. The Court heard the evidence and arguments of counsel and announced its decision for Plaintiff. Plaintiff now files a Final Judgment based on the Court’s decision.

The Court RENDERED judgment for Plaintiff on 6 April 2023. This written judgment memorializes that rendition.

1. Accordingly, the Court orders that Plaintiff recover the following from Defendants, jointly and severally:

a. Actual damages in the amount of $69,962.50, plus interest at the rate of 5% per annum,

b. Reasonable and necessary attorney fees in the amount of $60,934.00, for the prosecution of this case through this judgment.

c. If this matter is taken to any intermediate appellate court additional attorneys fees would reasonably be $60,000 if the plaintiff prevails on appeal.

d. If this matter is taken to Texas Supreme Court additional attorneys fees would reasonably be $120,000 if the plaintiff prevails on appeal.

e. Court costs in the amount of $2,034.00.

f. Post judgment interest at the rate of 5% per annum, compounded annually, from the date this judgment is rendered until all amounts are paid in full.

2. This supplemental judgment finally disposes of all claims and all parties and is appealable.

This appeal followed.

–5– STANDARD OF REVIEW

Review of a trial court’s dismissal of a case based on the grant of special

exceptions requires examination of two distinct rulings: (1) the decision to sustain

the special exceptions; and (2) the decision to dismiss the cause of action. Connolly

v.

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Bill Carey and Chantal Carey, Individually and as Trustee for the Smith Moore Williams Historical Trust v. Mosser Law PLLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bill-carey-and-chantal-carey-individually-and-as-trustee-for-the-smith-texapp-2024.