Caffe Ribs, Inc. v. State

Procedural entryThis page is a short order in Caffe Ribs, Inc. v. State. Read the opinion of the Court — 2010 Tex. App. LEXIS 10188
Court of Appeals of Texas·Decided December 28, 2010·No. 14-08-00057-CV·Published

Opinion

Reversed and Remanded and Memorandum Opinion filed December 28, 2010.

In The

Fourteenth Court of Appeals

___________________

NO. 14-08-00057-CV

___________________

Caffe Ribs, Inc., Appellant

V.

The State of Texas, Appellee

On Appeal from the County Civil Court at Law No. 3

Harris County, Texas

Trial Court Cause No. 839502

OPINION

          Caffe Ribs appeals from a judgment on a jury verdict awarding $4.5 million in this eminent domain proceeding for the State’s whole taking of a 7.5214 acre parcel of land and improvements.  In multiple issues, Caffe Ribs challenges the trial court’s evidentiary rulings.  We reverse and remand for a new trial because (1) evidence relating to an agreement to pay for costs associated with environmental contamination of the property erroneously was excluded at trial, and (2) exclusion of this evidence was harmful.

Background

            The State of Texas acquired the subject property as part of the construction, reconstruction, maintenance, and operation of the highway system.  The property is located on Old Katy Road near the northwest intersection of Beltway 8 and Interstate Highway 10.

            The property was used to manufacture and store oil field equipment beginning in 1955; over the next four decades, these activities resulted in environmental contamination.  From 1977 to 1988, Weatherford U.S., Inc. owned and used the property for drilling tool fabrication and repair.  Property improvements included a parts warehouse, assembly shop, display room, machine shop, and office.

            Although the Paul Revere Variable Annuity Insurance Company foreclosed on the property in 1988, Weatherford maintained operations at the property as a lessee until 1992.  Paul Revere sold the property to Caffe Ribs for $487,000 in February 1995.  Under the written agreement between Paul Revere and Caffe Ribs, it was “expressly understood and agreed that Buyer shall accept the conveyance of the Property in its present condition, ‘AS-IS, WHERE-IS[.]’”  Caffe Ribs also agreed “to accept the conveyance of the Property subject to any presently known or subsequently discovered Hazardous Materials or Hazardous Materials Contamination.”  Pursuant to this agreement, Paul Revere retained the exclusive right to evaluate and analyze the property’s environmental condition and to “take such action as it deems necessary or appropriate, in its sole discretion and expense, with regard to the environmental condition of the Property.”     

            In March 1996, Paul Revere and Weatherford executed an “Environmental Remediation Agreement” in which the parties[1] acknowledged:

            By Special Warranty Deed with Vendor’s Lien dated February 16, 1995, Paul Revere conveyed the Property to Caffe Ribs, Inc., a Utah, corporation (“Caffe Ribs”).  Paul Revere has agreed with Caffe Ribs to perform certain environmental work on the Property.  The belief that environmental work may be necessary is based on certain environmental assessments previously performed . . . .  The environmental assessments have detected certain Hazardous Materials Contamination on the Property.  Paul Revere and Weatherford desire to cooperate in (i) completing certain environmental assessments, (ii) performing certain environmental remediation work, and (iii) allocating the costs for such as set forth in this Remediation Agreement and wish to evidence their agreements hereby.

Using information provided by a consultant, Paul Revere and Weatherford agreed to determine the extent of Weatherford’s contribution to the subject property’s contamination.  Weatherford is responsible for remediation “to the extent of its proportional contribution to such contamination.”  The Environmental Remediation Agreement states:  “Without the express written consent of the other party, neither party may assign this Remediation Agreement nor delegate any duties or obligations hereunder except as expressly provided herein.”  By January 2005, the State had executed its own “Remediation and Indemnity Agreement” with Weatherford International, Inc.

On May 27, 2005, the State filed a petition seeking to condemn the property.  A Special Commissioners Hearing was held on July 19, 2005; Caffe Ribs, Paul Revere, Houston Community College, Spring Branch Independent School District, Harris County, and the City of Houston were jointly awarded $7,372,000 in damages for the condemnation of the property.  Caffe Ribs and the State filed objections to the Special Commissioners’ award, and the administrative proceeding was converted into a civil case.

On August 25, 2005, the State deposited the Special Commissioners’ award into the county civil court at law registry.  On May 15, 2006, the county civil court at law granted a request by Caffe Ribs and Paul Revere to withdraw the Special Commissioners’ award.  According to the order, Caffe Ribs was allowed to withdraw $6,459,500 from the court registry, and Paul Revere was allowed to withdraw $912,500.

In preparation for trial, Caffe Ribs and the State could not agree on the use of evidence relating to environmental contamination of the subject property.  Caffe Ribs subsequently filed a motion to exclude evidence of environmental contamination.  At the hearing on this motion, Caffe Ribs focused largely on its argument that the State had agreed to exclude environmental evidence by virtue of a Rule 11 agreement.  Caffe Ribs also argued:

[T]hese [contamination] issues shouldn’t come forward in Court because . . . State law requires the responsible party to reimburse the landowner, which is [Caffe Ribs] in this case, for the expenses of any environmental cleanup that may occur.  And there . . . was a contract in place before the date of taking to require Weatherford to cover certain expenses incurred by [Caffe Ribs] in this case . . . .

During the hearing, the court opined that both parties were “talking around” the one legal question it thought relevant, i.e., “What amount of testimony regarding the actual contamination of the property on the date of taking ought to come in?”  The court further stated it was “not sure that . . . who’s paying for the remediation is really addressing that.”  At a later hearing, the court informed the parties it was going to admit the State’s evidence of contamination.  This ruling is not challenged on appeal.

Caffe Ribs presented testimony at trial from appraiser Rudy Robinson, commercial real estate developer David Klein, and environmental engineer Richard Bost.

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