Donald Lee O'Hara, Jr. and Cheryl Ann O'Hara, on Behalf of Themselves and All Other Similarly Situated v. North American Mortgage Company

CourtCourt of Appeals of Texas
DecidedJune 28, 2002
Docket12-01-00193-CV
StatusPublished

This text of Donald Lee O'Hara, Jr. and Cheryl Ann O'Hara, on Behalf of Themselves and All Other Similarly Situated v. North American Mortgage Company (Donald Lee O'Hara, Jr. and Cheryl Ann O'Hara, on Behalf of Themselves and All Other Similarly Situated v. North American Mortgage Company) 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.

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Donald Lee O'Hara, Jr. and Cheryl Ann O'Hara, on Behalf of Themselves and All Other Similarly Situated v. North American Mortgage Company, (Tex. Ct. App. 2002).

Opinion

NO. 12-01-00193-CV



IN THE COURT OF APPEALS



TWELFTH COURT OF APPEALS DISTRICT

TYLER, TEXAS



DONALD LEE O'HARA, JR., ET AL.,

§
APPEAL FROM THE 115TH

APPELLANTS



V.

§
JUDICIAL DISTRICT COURT OF



NORTH AMERICAN

MORTGAGE COMPANY,

§
UPSHUR COUNTY, TEXAS

APPELLEE


The trial court certified a class action brought by the O'Haras against North American Mortgage Company for engaging in the unauthorized practice of law, and charging for those services. North American appealed, and this court reversed and remanded for decertification, without prejudice for refiling. North American then filed a petition for review with the supreme court, which was denied. The O'Haras amended their Motion for Class Certification, re-defining the class in order to satisfy our concerns about compulsory counterclaims. The trial court denied the Motion. In two issues, the O'Haras complain that the trial court abused its discretion when it refused to certify the class. We reverse and remand for certification of the class.



Background

The facts, as stated in this court's prior opinion, are not being disputed, and are as follows:



An evidentiary hearing was held in which the parties called witnesses and admitted documents into evidence. The undisputed evidence presented at the class certification hearing demonstrated that North American has a standard procedure through which it prepares loan documents. In connection with the O'Hara transaction, in October of 1994, North American approved a loan in the amount of $60,700 relating to the transfer of property through a general warranty deed. A non-attorney "loan closer" for North American then originated and documented the O'Hara loan using their computer system. Specifically, she input "variable information" into the program by responding to questions on her computer screen. In combination, those entries and the computer system created the O'Haras' deed of trust, note and general warranty deed, as well as other non-title loan documents.

The ultimate issue in the underlying case is whether this standardized system for the preparation of loan documents, which requires the input of data into the computer by clerical staff, constitutes the unauthorized practice of law and violates Texas Government Code Section 83.001. Tex. Gov't Code Ann. § 83.001(a) (Vernon 1998). Section 83.001 states that, except for certain professionals, no person may "charge or receive, either directly or indirectly, any compensation for all or any part of the preparation of a legal instrument affecting title to real property, including a deed, deed of trust, note, mortgage, and transfer or release of lien." Id. The statute provides that any sums charged or received in violation of this provision must be returned. Tex. Gov't Code Ann. § 83.005. It is undisputed that each borrower for which North American processes documents is charged a $125.00 "computer/clerical" fee.



North American v. O'Hara, et al., No. 12-99-00394-CV (Tex. App.- Tyler May 29, 2000, pet. dism'd w.o.j.) (not designated for publication).

In their second issue, the O'Haras argue that the only issue before this court is whether the new class definition meets the requirements of our prior decision, in which we held that all but the adequacy of representation requirement were satisfied. Id. (1) North American responds that Southwestern Refining Co. v. Bernal, 22 S.W.3d 425 (Tex. 2000), significantly changed the parameters under which certification of class actions should be considered and, therefore, the law of the case doctrine does not preclude reconsideration of all the issues relevant to class certification, particularly that of predominance.



Law of the Case

The law of the case doctrine provides that the initial determination of questions of law will generally be held to govern the case throughout the subsequent stages of the case. See Hudson v. Wakefield, 711 S.W.2d 628, 630 (Tex. 1986). The doctrine applies only to questions of law and not to questions of fact. Id. It operates to narrow the issues and provide uniformity of decisions and judicial economy. Id. However, when, as here, there has been a change in the controlling law between the time of the first and the second determinations, the law of the case doctrine does not preclude a court from reconsidering its previous determination. See McCrea v. Cubilla Condominium Corp., 769 S.W.2d 261, 263 (Tex. App.- Houston [1st Dist.] 1988, writ denied); see also Carroll v. State, 42 S.W.3d 129, 131 (Tex. Crim. App. 2001). The supreme court's decision in Bernal constitutes such an intervening decision. Thus, our prior determination regarding the O'Haras' case is not binding "law of the case." Accordingly, we overrule issue two.



Standard of Review

The O'Hara's first issue complains that the trial court erred when it denied their Motion for Class Certification. An appellate court should reverse a trial court's certification order only if the record shows that the trial court committed a clear abuse of discretion. E&V Slack, Inc. v. Shell Oil Co., 969 S.W.2d 565, 567 (Tex. App.- Austin 1998, no writ). An abuse of discretion occurs if the trial court acts without reference to any guiding principles or acts arbitrarily or unreasonably. Downer v. Aquamarine Operators, Inc., 701 S.W.2d 238, 242 (Tex. 1985). A failure to analyze or apply the law correctly is an abuse of discretion. Huie v. DeShazo, 922 S.W.2d 920, 927-28 (Tex. 1996); Walker v. Packer

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Donald Lee O'Hara, Jr. and Cheryl Ann O'Hara, on Behalf of Themselves and All Other Similarly Situated v. North American Mortgage Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/donald-lee-ohara-jr-and-cheryl-ann-ohara-on-behalf-texapp-2002.