Courtney Sanders, Individually and as Dependent Administrator of the Estate of William Paul Brown v. Charlotte Hathaway

CourtCourt of Appeals of Texas
DecidedJuly 9, 2019
Docket01-18-00661-CV
StatusPublished

This text of Courtney Sanders, Individually and as Dependent Administrator of the Estate of William Paul Brown v. Charlotte Hathaway (Courtney Sanders, Individually and as Dependent Administrator of the Estate of William Paul Brown v. Charlotte Hathaway) 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
Courtney Sanders, Individually and as Dependent Administrator of the Estate of William Paul Brown v. Charlotte Hathaway, (Tex. Ct. App. 2019).

Opinion

Opinion issued July 9, 2019

In The

Court of Appeals For The

First District of Texas ———————————— NO. 01-18-00661-CV ——————————— COURTNEY SANDERS, INDIVIDUALLY, AND AS DEPENDENT ADMINISTRATOR OF THE ESTATE OF WILLIAM PAUL BROWN, Appellant V. CHARLOTTE HATHAWAY, Appellee

On Appeal from the 239th District Court Brazoria County, Texas Trial Court Case No. 87060-CV

MEMORANDUM OPINION

Appellant Courtney Sanders, Individually, and as Dependent Administrator

of the Estate of William Paul Brown, appeals from the trial court’s order granting summary judgment in favor of appellee, Charlotte Hathaway, on Sanders’s causes

of action for common law fraud, fraudulent inducement, breach of fiduciary duty,

and to set aside contracts. In two issues, Sanders contends that the trial court erred

in granting summary judgment on her claims because (1) a fact issue exists with

regard to her claims of lack of mental capacity and undue influence and (2) the

discovery rule and fraudulent concealment doctrine tolled the accrual of her causes

of action. We affirm.

Background

Sanders and Hathaway are sisters and the daughters of William Paul Brown.

Brown died on September 10, 2010.

On June 10, 2016, Sanders filed suit against Hathaway asserting causes of

action for conversion, tortious interference with inheritance rights, fraudulent

inducement, common law fraud, breach of fiduciary duty. Sanders also sought to

set aside any distributions or transfers of, or change of beneficiary designations

regarding, real or personal property owned by Brown after January 2009 based on

Brown’s alleged lack of mental capacity to contract and undue influence exerted

over him by Hathaway. On November 16, 2016, Sanders filed her first amended

petition, omitting her conversion claim.

2 On November 3, 2017, Hathaway filed her first no-evidence motion for

summary judgment and second traditional motion for summary judgment.1 Sanders

filed her response to the motions on November 21, 2017. The summary judgment

evidence before the trial court, which included the transcripts of Sanders’s and

Hathaway’s depositions, Hathaway’s affidavit, certified copies of the deeds, and

Brown’s medical records, showed the following:

• Prior to his death, Brown lived alone in a trailer on his property. Hathaway lived in a nearby mobile home on Brown’s property and Sanders lived more than 300 miles away.

• Brown had a long history of heavy alcohol use and suffered from jaundice and cirrhosis of the liver. In addition to taking the pain medication, Darvon, Brown took Oxycontin during a two-week period in April or May 2010. When the Oxycontin caused him to hallucinate, Brown stopped taking the medication.

• On March 17, 2010, approximately six months before he died, Brown changed the beneficiary designations on three of his four insurance policies, naming Hathaway as sole beneficiary (“beneficiary changes”). On his fourth policy, Sanders and Hathaway remained co-beneficiaries.

• On March 17, 2010, Brown also executed four warranty deeds transferring his real property to Hathaway (“deeds”). The deeds, which were signed and notarized, were recorded in the property records of Brazoria County.

• Five days later, on March 22, 2010, Brown executed documents at his financial institution, the Associated Credit Union, making his checking, savings, and share certificates accounts payable on death to Hathaway

1 Hathaway previously filed a traditional motion for summary judgment which was denied on January 24, 2017.

3 (“payable on death accounts”). The beneficiary changes, deeds, and payable on death accounts disposed of all of Brown’s property except for household furnishings and personal effects.

• Sanders typically visited Brown four times a year and, in 2010, visited him twice. According to Sanders, Brown was able to care for himself, including feeding and dressing himself.

• In 2010, Hathaway visited Brown every day for approximately two hours, ensured that he took his medication, accompanied him to his doctor visits, made sure he had groceries, and occasionally cooked for him.

• When several of his friends passed away, Brown told Hathaway that he wanted to get his legal affairs in order. Brown, who could not type, sat next to Hathaway and gave her instructions while she created a declaration of trust and durable power of attorney using a will maker computer program. It is undisputed that the trust was never funded.

• On September 10, 2010, Brown died. On September 11, 2010, Hathaway told Sanders that their father had passed away.

• On September 12, 2010, two days after Brown’s death, Hathaway told Sanders that Brown did not have much when he passed away, and that what little remained he left to Hathaway in a trust.

• Sanders knew that she and Hathaway were to receive $10,000 each in life insurance proceeds but she did not know anything about Brown’s financial situation. Sanders also knew prior to Brown’s death that he had some property, but she did not know the nature and extent of it.

• In March 2014, Sanders learned from her uncle that Brown had assets worth approximately $1,000,000 before he died.

• On June 6, 2014, Sander’s attorney sent a letter to Hathaway requesting documentation concerning Brown’s deed transfers, beneficiary designations on his life insurance policies, and bank accounts.

4 • On September 9, 2014, Sanders applied for the administration of Brown’s estate.

Following a hearing, the trial court granted Hathaway’s no-evidence and

traditional summary judgment motions on June 26, 2018. On July 25, 2018, Sanders

filed a motion for new trial which was overruled by operation of law. This appeal

followed.

Discussion

On appeal, Sanders contends that the trial court erred in granting summary

judgment on her claims because (1) a fact issue exists with regard to her claims of

lack of mental capacity and undue influence, (2) the discovery rule and doctrine of

fraudulent concealment tolled the accrual of her causes of action, and (3) the

evidence is sufficient to create a fact issue on her claims of common law fraud and

breach of fiduciary duty.

A. Standard of Review

We review a trial court’s grant of summary judgment de novo. Travelers Ins.

Co. v. Joachim, 315 S.W.3d 860, 862 (Tex. 2010). When reviewing a summary

judgment motion, we must (1) take as true all evidence favorable to the nonmovant

and (2) indulge every reasonable inference and resolve any doubts in the

nonmovant’s favor. Valence Operating Co. v. Dorsett, 164 S.W.3d 656, 661 (Tex.

2005) (citing Provident Life & Accident Ins. Co. v. Knott, 128 S.W.3d 211, 215 (Tex.

2003)). If a trial court grants summary judgment without specifying the grounds for 5 granting the motion, we must uphold the trial court’s judgment if any one of the

grounds in the motion is meritorious. Beverick v. Koch Power, Inc., 186 S.W.3d

145, 148 (Tex. App.—Houston [1st Dist.] 2005, pet. denied).

In a traditional summary judgment motion, the movant has the burden to show

that no genuine issue of material fact exists and that the trial court should grant

judgment as a matter of law. TEX. R. CIV. P. 166a(c); KPMG Peat Marwick v.

Harrison Cty. Hous. Fin. Corp., 988 S.W.2d 746, 748 (Tex. 1999). A defendant

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Courtney Sanders, Individually and as Dependent Administrator of the Estate of William Paul Brown v. Charlotte Hathaway, Counsel Stack Legal Research, https://law.counselstack.com/opinion/courtney-sanders-individually-and-as-dependent-administrator-of-the-estate-texapp-2019.