David Patrick v. American Express National Bank

CourtCourt of Appeals of Texas
DecidedMarch 7, 2024
Docket01-22-00795-CV
StatusPublished

This text of David Patrick v. American Express National Bank (David Patrick v. American Express National Bank) 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
David Patrick v. American Express National Bank, (Tex. Ct. App. 2024).

Opinion

Opinion issued March 7, 2024

In The

Court of Appeals For The

First District of Texas ———————————— NO. 01-22-00795-CV ——————————— DAVID R. PATRICK, Appellant V. AMERICAN EXPRESS NATIONAL BANK, Appellee

On Appeal from the 268th District Court Fort Bend County, Texas Trial Court Case No. 21-DCV-283812

MEMORANDUM OPINION

This is a suit to recover a credit card debt. American Express National Bank

sued David R. Patrick, individually, and his limited liability company (the “LLC”),1

1 The LLC, E Solutions Tech Svc, also known as eSolutions Technologies & Services, LLC, which Patrick asserts is insolvent and defunct, is not a party to this appeal. for breach of contract and account stated, alleging they defaulted on a credit card

agreement by failing to pay as agreed. American Express moved for summary

judgment on its claims, asserting Patrick and the LLC were jointly and severally

liable on the debt. The trial court granted summary judgment for American Express.

Patrick now appeals pro se. In his sole issue, Patrick contends that the

summary judgment is erroneous because American Express failed to conclusively

establish his individual liability on the debt.

We affirm.

Background

American Express alleged that it entered into a Cardmember Agreement with

Patrick and the LLC, provided an American Express credit card, and extended cash

advances or payments to third parties on their behalf. It further alleged that, under

the terms of the Agreement, Patrick and the LLC agreed to repay the advances, along

with interest and finance charges. However, despite demand, they failed or refused

to pay as agreed. Patrick answered and asserted that he was not liable for the debt

in his individual capacity.

American Express then moved for summary judgment on its claims against

both Patrick and the LLC. American Express argued that it was entitled to a

summary judgment on its breach-of-contract claim because its evidence

conclusively established that it issued a credit card to Patrick and the LLC, and that,

2 by keeping and using the card, Patrick and the LLC agreed to the terms of the

Cardmember Agreement. American Express further argued that it conclusively

established that it performed its obligations under the Agreement; that Patrick and

the LLC breached the Agreement by failing or refusing to pay as agreed; and that

such breach proximately caused American Express damages in the amount of

$13,005.60.

American Express also maintained that it was entitled to judgment on its claim

for account stated2 because its evidence established: (1) a series of transactions

between the parties giving rise to the indebtedness of Patrick and the LLC to

American Express; (2) an agreement between the parties fixing an amount due; and

(3) implied promises by Patrick and the LLC to pay the indebtedness.

In his summary-judgment response, Patrick asserted that the LLC was

registered in Texas in 2011 and that he is its sole member. He contended that, as a

member of the LLC, he could not be personally liable for its debt under Texas law.

He asserted that, in 2016, American Express invited him to open a corporate account,

and he provided the LLC’s company agreement and tax identification number. The

American Express representative “confirmed that [he] would not be personally

2 A common-law claim for “account stated” is not a “suit on a sworn account,” which is “not available in a suit to recover credit card debt.” Williams v. Unifund CCR Partners, 264 S.W.3d 231, 235 (Tex. App.—Houston [1st Dist.] 2008, no pet.).

3 responsible for the debt accrued on this account,” and he “never agreed verbally or

in writing to be personally liable for the debt(s) of [the LLC].”

After conducting a virtual hearing, the trial court rendered summary judgment

for American Express in all things, awarding damages, jointly and severally, against

Patrick and the LLC in the amount of $13,005.60 and costs of $482.05.3

Summary Judgment

Patrick argues in his sole issue that the trial court erred in granting summary

judgment for American Express against him because it failed to conclusively

establish the elements of its claims against him in his individual capacity.

3 On September 26, 2022, American Express filed a “Notice of Remote Hearing,” setting its summary judgment motion for a virtual hearing on September 30, 2022. On that same day, the trial court inadvertently signed a “Final Summary Judgment” in favor of American Express. At the September 30 hearing, the trial court acknowledged that it had prematurely granted American Express’s motion and withdrew its prior summary judgment. At the conclusion of the hearing, the trial court orally granted summary judgment for American Express. The record before us does not reflect that the trial court’s oral pronouncement was ever memorialized in a written judgment. A judgment, however, is “‘rendered’ when the trial court’s decision upon the matter submitted to it for resolution is officially announced either orally in open court or by memorandum filed with the clerk.” In re Bill Heard Chevrolet, Ltd., 209 S.W.3d 311, 314 n.5 (Tex. App.—Houston [1st Dist.] 2006, orig. proceeding) (emphasis added). Once a judgment is rendered by oral pronouncement, the entry of a written judgment is purely a ministerial act. Id. at 314. Accordingly, the trial court’s oral rendition in open court here constitutes the final judgment in this case.

4 Standard of Review

We review a trial court’s grant of summary judgment de novo. Eagle Oil &

Gas Co. v. TRO-X, L.P., 619 S.W.3d 699, 705 (Tex. 2021). In a traditional motion

for summary judgment, the moving party must show that no genuine dispute exists

as to any material fact such that the party is entitled to judgment as a matter of law.

TEX. R. CIV. P. 166a(c). We review the summary judgment record in the light most

favorable to the nonmovant, indulging every reasonable inference and resolving any

doubts against the motion. Eagle Oil & Gas Co., 619 S.W.3d at 705.

If the moving party establishes its entitlement to judgment as a matter of law,

the burden then shifts to the non-movant to present countervailing evidence that

raises a genuine issue of material fact on the movant’s claims. City of Hous. v. Clear

Creek Basin Authority, 589 S.W.2d 671, 678 (Tex. 1979). Evidence raises a genuine

issue of material fact if reasonable people could differ in their conclusions in light

of all of the summary-judgment evidence. Goodyear Tire & Rubber Co. v. Mayes,

236 S.W.3d 754, 755 (Tex. 2007).

When, as here, the trial court’s order granting summary judgment does not

specify the grounds relied upon, we will affirm the summary judgment if any of the

grounds are meritorious. FM Props. Operating Co. v. City of Austin, 22 S.W.3d 868,

872 (Tex. 2000).

5 Breach of Contract

To be entitled to summary judgment on its breach-of-contract claim against

Patrick, American Express must establish, as a matter of law: (1) a valid contract

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David Patrick v. American Express National Bank, Counsel Stack Legal Research, https://law.counselstack.com/opinion/david-patrick-v-american-express-national-bank-texapp-2024.