Cole Chemical & Distributing, Inc. v. Brendan F. Gowing, Individually and as Guarantor

CourtCourt of Appeals of Texas
DecidedMarch 15, 2005
Docket14-03-01092-CV
StatusPublished

This text of Cole Chemical & Distributing, Inc. v. Brendan F. Gowing, Individually and as Guarantor (Cole Chemical & Distributing, Inc. v. Brendan F. Gowing, Individually and as Guarantor) 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
Cole Chemical & Distributing, Inc. v. Brendan F. Gowing, Individually and as Guarantor, (Tex. Ct. App. 2005).

Opinion

Affirmed in Part, Reversed and Remanded in Part, and Opinion filed March 15, 2005

Affirmed in Part, Reversed and Remanded in Part, and Opinion filed March 15, 2005.

In The

Fourteenth Court of Appeals

____________

NO. 14-03-01092-CV

COLE CHEMICAL & DISTRIBUTING, INC., Appellant/Cross-Appellee

V.

BRENDAN F. GOWING, INDIVIDUALLY AND AS GUARANTOR, Appellee/Cross-Appellant

On Appeal from the County Court at Law No. 3

Harris County, Texas

Trial Court Cause No. 776,624

O P I N I O N

This case involves a commercial landlord/tenant dispute that ultimately resulted in the tenant, appellee/cross-appellant Brendan F. Gowing, individually and as guarantor, being locked out of his leased property.  The landlord, appellant/cross-appellee Cole Chemical & Distributing, Inc. (“Cole”), sued Gowing for breach of the rental agreement to recover unpaid rent and late fees.  Gowing asserted the affirmative defense of failure to mitigate damages and counterclaimed based on Cole’s failure to hang a post-lockout notice as required by Texas Property Code section 93.002(f).  We affirm in part and reverse and remand in part.


                          Factual and Procedural Background

During the second year of a two-year lease, Gowing became delinquent in his rental payments.  Each month’s rent included a basic monthly payment of $3,908.58 plus an additional rent equal to a prorata share of rental escalations.  After several telephone calls produced no results, Cole sent a representative to the property to personally deliver an invoice to Gowing and learned for the first time that Gowing had moved out of the space and into a larger space across the hall.  Cole delivered the invoice to the new space and then had the locks changed on the old space.  The payment dispute continued, and Cole sued Gowing for breach of the rental agreement.

Four and a half months after the lockout, Cole and Gowing reached an agreement to mitigate damages that allowed Gowing to reoccupy the leased space for the remainder of the contract term.  Cole maintained its suit to recover unpaid rent and late fees in addition to attorneys’ fees in the amount of $27,100.  After a bench trial, the trial court found that Gowing breached the rental agreement but awarded only $976.52 in damages after deducting $19,220.88 based on its finding that Cole had failed to make reasonable efforts to re-let the space during the lockout period and therefore failed to mitigate its damages.  The trial court also awarded Cole $2,500 in attorneys’ fees.

In four issues, Cole challenges the trial court’s award of damages and attorneys’ fees.  Cole argues that the trial court improperly shifted the burden to Cole to prove that it mitigated its damages during the lockout period and that, viewed with the proper allocation of burdens, the evidence is insufficient to support a finding that Cole failed to mitigate its damages.  The trial court refused to award Cole damages for late fees as specified in the contract, and Cole claims this was error as well.  Finally, Cole contends that the trial court abused its discretion in awarding only $2,500 in attorneys’ fees.[1]


In his cross-appeal, Gowing argues that the trial court erred in rejecting his counterclaim based on Cole’s failure to post a notice on the door of the leased property after the lockout specifying where Gowing could obtain new keys upon paying full rent.  See Tex. Prop. Code Ann. § 93.002(f) (Vernon 1995).

                                                      Analysis

                                             Mitigation of Damages

The Property Code provides that “[a] landlord has a duty to mitigate damages if a tenant abandons the leased premises in violation of the lease.”  Tex. Prop. Code Ann. § 91.006(a) (Vernon Supp. 2004–2005).  Though it is the landlord’s duty to mitigate damages, the tenant has the burden of proving “that the landlord has mitigated or failed to mitigate damages and the amount by which the landlord reduced or could have reduced its damages.”  Austin Hill Country Realty, Inc. v. Palisades Plaza, Inc., 948 S.W.2d 293, 299 (Tex. 1997).


The trial court found that Cole’s duty to mitigate commenced on the date of the lockout and that Cole failed to exercise reasonable efforts to mitigate its damages during the lockout period by making reasonable efforts to find a new tenant.  In its second issue, Cole challenges the legal and factual sufficiency of the evidence to support the trial court’s finding that it failed to mitigate.[2]  In reviewing a trial court’s findings of fact and conclusions of law for factual and legal sufficiency, we apply the same standards as when reviewing the sufficiency of the evidence to support a jury’s findings.  Rauscher Pierce Refsnes, Inc. v. Great Southwest Sav., F.A., 923 S.W.2d 112, 115 (Tex. App.—Houston [14th Dist.] 1996, no writ).  In reviewing factual sufficiency, we examine the entire record, considering both the evidence in favor of, and contrary to, the challenged findings.  See Cain v. Bain, 709 S.W.2d 175, 176 (Tex. 1986).  After considering and weighing all the evidence, we set aside a fact finding only if it is so contrary to the overwhelming weight of the evidence as to be clearly wrong and unjust.

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Cole Chemical & Distributing, Inc. v. Brendan F. Gowing, Individually and as Guarantor, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cole-chemical-distributing-inc-v-brendan-f-gowing--texapp-2005.