Citibank (South Dakota), N.A. v. Michael A. Tate

CourtCourt of Appeals of Texas
DecidedDecember 16, 2010
Docket01-09-00320-CV
StatusPublished

This text of Citibank (South Dakota), N.A. v. Michael A. Tate (Citibank (South Dakota), N.A. v. Michael A. Tate) 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
Citibank (South Dakota), N.A. v. Michael A. Tate, (Tex. Ct. App. 2010).

Opinion

Opinion issued December 16, 2010

In The

Court of Appeals

For The

First District of Texas

————————————

NO. 01-09-00320-CV

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Citibank (South Dakota), N.A., Appellant

V.

Michael A. Tate, Appellee

On Appeal from the County Court at Law No. 4

Fort Bend County, Texas

Trial Court Case No. 05-CCV-026232

MEMORANDUM OPINION

          Citibank (South Dakota), N.A. appeals a directed verdict in favor of Michael A. Tate in its suit for unpaid credit card debt.  Citibank contends that the trial court erroneously excluded the billing statements and notices informing Tate of changes in his credit card agreement.  Because Citibank properly established the applicability of the business-records exception, we reverse and remand for further proceedings.

I.                  Background

Citibank (South Dakota), N.A. sued Michael A. Tate to recover unpaid debt on a credit card account.  During trial, Citibank sought to introduce the billing statements from Tate’s account through the testimony of Rhonda Hedges, an employee of Citicorp Credit Services, Inc.  Hedges testified without objection that Citicorp Credit Services and Citibank were both wholly owned subsidiaries of Citigroup and that pursuant to a contract, Citicorp Credit Services provided administrative services for Citibank’s credit card accounts.  These services included collections, customer service, litigation support, and issuance of credit cards and billing statements.

Hedges identified exhibits 2–9 as notices regarding changes in Tate’s credit card agreement and testified, without objection, that she had located these documents in Citibank’s files.  Citibank offered these exhibits into evidence, and Tate’s lawyer objected to the lack of a proper predicate for lack of a showing that these notices were timely sent to Tate in accordance with the credit card agreement.  Although the trial court initially observed that this objection went to the weight of the evidence, not its admissibility, the trial court admitted exhibits 2-9 for the limited purpose of being examples of Citibank’s records, subject to Citibank laying a proper predicate.  See Tex. R. Evid. 104(b).

The following day, outside the presence of the jury, Tate’s lawyer raised a discovery issue.  During discovery, Tate sought production of “[t]he contract that [Citibank has] with Citi Credit Services (USA), Inc., related to the collection or handling of [Tate’s] Account.”  Citibank objected to the request on several grounds including materiality, relevance, vagueness, and confidentiality.  Tate never moved to compel production, nor did he otherwise seek a ruling on Citibank’s objections.  Nevertheless, based on Citibank’s failure to produce its contract with Citicorp Credit Services, Tate objected that all of Hedges’s testimony from the prior day was hearsay.  After hearing argument from both sides, the trial court stated that the Citicorp Credit Services contract was inadmissible, and it ruled that exhibits 2 through 9 were also inadmissible.  Citibank offered the contract for admission into evidence later that same day, and the trial court again ruled that it was inadmissible.

After the trial court’s exclusion of exhibits 2-9, Hedges testified that she had been employed by Citicorp Credit Services for nearly seven years.  She identified exhibit 10, which was comprised of monthly billing statements for Tate’s account from January 1998 through December 2004.  She testified that Citicorp Credit Services generates similar billing statements and maintains the records for all of Citibank’s credit card accounts.  She also testified without objection that (1) exhibit 10 was made at or near the time of the information recorded therein, (2) exhibit 10 was made by a person or persons with knowledge of the information recorded therein, (3) it is in the regular course of Citicorp Credit Services’s business to make such records, and (4) it is in the regular course of Citicorp Credit Services’s business to keep such records.

Tate’s lawyer objected to exhibit 10 because the contract between Citibank and Citicorp Credit Services was not produced during discovery, and the trial court sustained the objection, saying:

It was not shown what right she has to have any access to Citibank records.  The fact they are in possession of Citicorp or whatever this other entity is does not tie this to any right to testify as to anything regarding this particular case where the Plaintiff is Citibank.

          Citibank argued that Hedges’s testimony satisfied the requirements of the business records exception to the hearsay rule.  The trial court observed that Hedges never testified that she was the custodian of the records of Citibank, that the only way she could be a custodian of the records would be pursuant to a contract, and that any such contract was inadmissible because it was not produced during discovery. 

Citibank made an offer of proof, wherein Hedges testified unequivocally that she had been the custodian of Citibank’s records since 2002.  In response to counsel’s questions, she again testified to all of the requirements of the business records exception regarding exhibit 10.  Exhibits 2–10 were attached to the record as part of Citibank’s offer of proof.  Citibank rested, and the trial court granted Tate’s motion for directed verdict. 

II.               Standard of review

We review a trial court’s decision to admit or exclude evidence for an abuse of discretion.  Bay Area Healthcare Grp., Ltd. v. McShane, 239 S.W.3d 231, 234 (Tex.

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Bluebook (online)
Citibank (South Dakota), N.A. v. Michael A. Tate, Counsel Stack Legal Research, https://law.counselstack.com/opinion/citibank-south-dakota-na-v-michael-a-tate-texapp-2010.