CHCA East Houston, L.P. D/B/A East Houston Regional Medical Center v. Bill Henderson, D.D.S.

CourtCourt of Appeals of Texas
DecidedJanuary 9, 2003
Docket14-01-00967-CV
StatusPublished

This text of CHCA East Houston, L.P. D/B/A East Houston Regional Medical Center v. Bill Henderson, D.D.S. (CHCA East Houston, L.P. D/B/A East Houston Regional Medical Center v. Bill Henderson, D.D.S.) 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
CHCA East Houston, L.P. D/B/A East Houston Regional Medical Center v. Bill Henderson, D.D.S., (Tex. Ct. App. 2003).

Opinion

Affirmed and Opinion filed January 9, 2003

Affirmed and Opinion filed January 9, 2003.

In The

Fourteenth Court of Appeals

____________

NO.  14-01-00967-CV

CHCA EAST HOUSTON, L.P. d/b/a EAST HOUSTON REGIONAL MEDICAL CENTER, Appellant

V.

BILL HENDERSON, D.D.S., Appellee

On Appeal from the County Civil Court at Law No. 4

Harris County, Texas

Trial Court Cause No. 713, 337

O P I N I O N

This relatively simple case raises relatively complex problems.  For many years, appellee Bill Henderson has occupied a dental office in a professional building in east Houston.  Although the lease he signed in 1991 expired in 1994, he continued under the terms of that lease on a month-to-month basis.  For several months in 1996, he admits he paid no rent due to hip and knee problems.  In September 1996, he signed a new lease, and it is undisputed he has not missed any rental payments since.


But the parties disagree whether he is current.  Appellant, CHCA East Houston, L.P. d/b/a East Houston Regional Medical Center (AEast Houston@), applied some of the payments made after October 1996 to rents allegedly due under the first lease, thus leaving a shortfall of $10,872 under the second.  See W. E. Grace Mfg. Co. v. Levin, 506 S.W.2d 580, 585 (Tex. 1974) (holding that unless debtor specifically directs payment, creditor may apply payments to any valid claim against debtor).  Henderson objected to this offset, asserting East Houston had no assignment or other authority to collect rent under the first lease or apply payments to it.  After a bench trial, the trial court agreed.

I.  Motion to Dismiss Appeal

At the outset, Henderson argues we must dismiss this appeal because appellant East Houston was not a party to the trial court=s judgment.  The suit below was filed by, and judgment was entered against, Sunbelt Regional Medical Center, Inc. d/b/a East Houston Regional Medical Center (ASunbelt, Inc.@).  At trial, documents were introduced showing that Sunbelt, Inc. sold and assigned all its assets (including Henderson=s account receivable) to East Houston in a series of transactions on February 29, 2000.

An assignee, though not a party below, may file an appeal in its own name.  See Motor Vehicle Bd. of Tex. Dept. of Transp. v. El Paso Indep. Auto. Dealers Ass=n, Inc., 1 S.W.3d 108, 110 (Tex. 1999) (discussing doctrine of virtual representation).  Accordingly, we hold East Houston as assignee of the plaintiff below may appeal.  We deny Henderson=s motion to dismiss and his related claim for damages for a frivolous appeal.

II.  Standing, Capacity, or Something Else?


 Henderson=s primary defense at trial was that Sunbelt, Inc. (the plaintiff below, and East Houston=s assignor) was not a party to the first lease, and had no assignment or other authority to apply payments to it.  Because he objects that Sunbelt, Inc. was not a proper party (rather than merely improperly named), the allegation is one of misidentification.  See Enserch Corp. v. Parker, 794 S.W.2d 2, 4-5 (Tex. 1990) (distinguishing between Amisnomer@ cases involving correct party incorrectly named, and Amisidentification@ cases involving incorrect party).  But there appears to be some doubt whether misidentification raises a question of standing, capacity, or something else.  The answer is critical, as it determines the time and manner of raising an objection.

The trial court treated the question as one of standing, concluding that Sunbelt, Inc. had no standing to enforce the first lease.  Standing focuses on whether the plaintiff has a sufficient personal stake in a controversy.  See Nootsie, Ltd.  v. Williamson County Appraisal District, 925 S.W.2d 659, 661 (Tex. 1996).  As a component of subject-matter jurisdiction, it cannot be waived, and may be asserted for the first time on appeal.  Id. at 662.

Several appellate courts, however, have treated misidentification of a contract party as a question of capacity.  For example, our colleagues downstairs have held that a complaint that the plaintiff was not the successor-in-interest of the original landlord was one of capacity.  See Nine Greenway Ltd. v. Heard, Goggan, et al., 875 S.W.2d 784, 787 (Tex. App.CHouston [1st Dist.] 1994, writ denied).[1] 

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CHCA East Houston, L.P. D/B/A East Houston Regional Medical Center v. Bill Henderson, D.D.S., Counsel Stack Legal Research, https://law.counselstack.com/opinion/chca-east-houston-lp-dba-east-houston-regional-med-texapp-2003.