Coastal Banc Ssb v. Chase Bank of Texas, N.A., F/K/A Texas Commerce Bank National Association

CourtCourt of Appeals of Texas
DecidedFebruary 12, 2004
Docket01-01-01013-CV
StatusPublished

This text of Coastal Banc Ssb v. Chase Bank of Texas, N.A., F/K/A Texas Commerce Bank National Association (Coastal Banc Ssb v. Chase Bank of Texas, N.A., F/K/A Texas Commerce Bank National Association) 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
Coastal Banc Ssb v. Chase Bank of Texas, N.A., F/K/A Texas Commerce Bank National Association, (Tex. Ct. App. 2004).

Opinion

Opinion Issued February 12, 2004





In The

Court of Appeals

For The

First District of Texas





NO. 01-01-01013-CV





COASTAL BANK SSB, Appellant


V.


CHASE BANK OF TEXAS, N.A., f/k/a COMMERCE BANK NATIONAL ASSOCIATION, Appellee





On Appeal from the 333rd District Court

Harris County, Texas

Trial Court Cause No. 00-01212





O P I N I O N


          This is an appeal of a summary judgment rendered in favor of appellee/defendant, Chase Bank of Texas, N.A., f/k/a Commerce Bank National Association, in a suit for fraudulent inducement and negligent misrepresentation brought by appellant/plaintiff Coastal Bank ssb. In three issues presented for review, Coastal contends the trial court erred in rendering summary judgment because there was substantial evidence of fraudulent inducement and negligent misrepresentation and because Chase did not negate the element of reliance as a matter of law. We must determine whether the waivers/disclaimers that Coastal signed as part of its contract with Chase defeat its causes of action. Because we conclude that they do, we affirm.

FACTS

          In the summer of 1998, Chase invited Coastal to join a syndicate of banks that had been lending cash to MCA, a Michigan-based mortgage company. At MCA’s request, Chase was increasing the amount of MCA’s available credit to $300 million and was seeking the participation of additional banks to accomplish this. Coastal agreed in August 1998 to invest $10 million in what is known as a “seasoned” line of credit (one containing higher-risk loans and, consequently, paying a higher rate of interest) as a member of the syndicate of banks lending money to MCA; it signed the contract with Chase in November 1998. Less than a month later, the syndicated banks commenced an inquiry into MCA’s financial status and discovered that MCA had been systematically defrauding the banks by double-pledging millions of dollars in loans. Ultimately, all of the banks in the syndicate lost a considerable amount of money; Coastal’s losses totaled approximately $7.5 million.

          Before Coastal signed the contract agreeing to participate as a member of the bank syndicate, Chase provided information to Coastal about MCA in the form of a confidential memorandum to be used in Coastal’s decision-making process. Both the confidential memorandum and the contract contained clauses stating that the “participant” (Coastal) had completed its own credit analysis, independently and without reliance on the “Lead” (Chase), but based instead on the borrower’s (MCA’s) financial statements.

          Evidently, Coastal performed only a perfunctory credit analysis. Coastal did not attend a meeting that was held by MCA and various syndicate members to discuss the investment; nor did Coastal seek or obtain any credit information directly from MCA. Instead, it limited its inquiry to Chase officers and to a loan officer at the Bank of New York with whom a Coastal officer, Don Mach, was familiar. When Mach inquired about MCA’s history with Chase, Audrey Lokker—the Chase loan officer responsible for the MCA credit—responded that the history was “very satisfactory.” Coastal apparently made no further inquiries.

          After MCA’s fraud was discovered and Coastal had lost the better part of its investment, Coastal sued Chase for fraud, fraudulent inducement and negligent misrepresentation, based primarily on Lokker’s statement that Chase’s history with MCA was “very satisfactory.” Chase moved for summary judgment on the grounds that there was no evidence to support Coastal’s claims and that Chase had negated reliance—an essential element of all claims—as a matter of law. The trial court granted Chase’s motion and rendered a take-nothing summary judgment against Coastal, from which Coastal now appeals.

DISCUSSION

          In three issues presented for review, Coastal argues that the trial court improperly rendered summary judgment because Coastal produced more than a scintilla of evidence of fraud and negligent misrepresentation, and because Chase did not negate reliance as a matter of law.

          Standard of Review

          Summary judgment is appropriate only when the movant shows that there are no disputed issues of material fact and the moving party is entitled to judgment as a matter of law on the issues set out in the motion. Tex. R. Civ. P. 166a(c); Tex. Commerce Bank, N.A. v. Grizzle, 96 S.W.3d 240, 252 (Tex. 2002). As the defendant moving for summary judgment, Chase was required to disprove at least one essential element of each of Coastal’s theories of recovery as a matter of law. City of Houston v. Clear Creek Basin Auth., 589 S.W.2d 671, 679 (Tex. 1979). A no-evidence motion for summary judgment is properly granted if, after adequate time for discovery, the non-movant fails to produce more than a scintilla of evidence raising a genuine issue of material fact on the challenged elements. See Tex. R. Civ. P. 166a(i); Flameout Design & Fabrication, Inc. v. Pennzoil Caspian Corp., 994 S.W.2d 830, 834 (Tex. App.—Houston [1st Dist.] 1999, no pet.). The court must grant the motion unless the non-movant produces summary judgment evidence that raises a genuine issue of material fact. Id.

          We hold that Chase disproved the element of reliance common to fraud, fraudulent inducement, and negligent misrepresentation as a mater of law.

          Negligent Misrepresentation, Fraud, and Fraudulent Inducement

          In its third issue, Coastal contends that Chase failed to establish as a matter of law that Coastal did not rely on Chase’s misrepresentations. Coastal contends that Lokker’s statement that Chase’s history with MCA was “very satisfactory” was an actionable affirmative misrepresentation made to fraudulently induce Coastal into participating in the syndicate. Coastal further contends that Chase violated an affirmative duty to disclose information concerning MCA, thus committing fraud.

          

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Coastal Banc Ssb v. Chase Bank of Texas, N.A., F/K/A Texas Commerce Bank National Association, Counsel Stack Legal Research, https://law.counselstack.com/opinion/coastal-banc-ssb-v-chase-bank-of-texas-na-fka-texa-texapp-2004.