Doris Brown v. Ultramar Diamond Shamrock Corp.

CourtCourt of Appeals of Texas
DecidedAugust 12, 2004
Docket13-02-00535-CV
StatusPublished

This text of Doris Brown v. Ultramar Diamond Shamrock Corp. (Doris Brown v. Ultramar Diamond Shamrock Corp.) 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
Doris Brown v. Ultramar Diamond Shamrock Corp., (Tex. Ct. App. 2004).

Opinion





                                 NUMBER 13-02-535-CV


COURT OF APPEALS

THIRTEENTH DISTRICT OF TEXAS


CORPUS CHRISTI - EDINBURG




DORIS BROWN,                                                                          Appellant,


v.


ULTRAMAR DIAMOND

SHAMROCK CORP., ET AL.,                                                      Appellees.





On appeal from the 36th District Court

of Live Oak County, Texas.





MEMORANDUM OPINION


Before Chief Justice Valdez and Justices Rodriguez and Castillo


Memorandum Opinion by Justice Castillo


         Appellant Doris Brown alleged causes of action stemming from a spill of wastewater onto her property from a Diamond Shamrock operation. The trial court granted Diamond Shamrock's no-evidence motion for summary judgment. By three issues, Brown complains that: (1) summary judgment was not supported by law or fact; (2) the trial court abused its discretion in disregarding Brown's summary-judgment evidence; and (3) the trial court abused its discretion in striking Brown's summary-judgment response. We affirm in part and reverse and remand in part.

I. THE RECORD

A. Brown's Claims

1. Brown's Live Pleading

         The trial court issued a docket control order that set a pleading deadline of April 1, 2002. Diamond Shamrock moved for summary judgment on April 18, 2002. Brown filed a motion for leave to file her fourth amended petition on May 16, 2002. On June 4, 2002, Diamond Shamrock filed a response opposing the motion for leave, arguing that the amendment came after the pleadings deadline and less than seven days before the noticed summary-judgment submission date of May 17, 2002. The record does not reflect a ruling on the motion for leave. As a preliminary matter, we first determine which pleading was Brown's live pleading for purpose of the summary-judgment proceeding.

a. Pleading Amendment Deadlines

         We note that a summary-judgment hearing is considered a "trial" for purposes of rule 63. See Tex. R. Civ. P. 63; see also Goswami v. Metropolitan Sav. & Loan Assoc., 751 S.W.2d 487, 490 (Tex. 1988). Thus, rule 63 requires leave of court to amend a pleading within seven days of a summary-judgment hearing. Goswami, 751 S.W.2d at 490. However, rule 63 is liberally construed. Lee v. Key West Towers, Inc., 783 S.W.2d 586, 588 (Tex. 1989); Diesel Fuel Injection Serv. v. Gabourel, 893 S.W.2d 610, 611 (Tex. App.–Corpus Christi 1994, no writ). Thus, Texas appellate courts apply a liberal interpretation in determining whether a trial court granted leave to file an amended pleading beyond the prescribed deadline. See Goswami, 751 S.W.2d at 490 (finding that trial court granted leave to file late pleading where pleading was filed within seven days of summary-judgment proceeding); see also Johnson v. Rollen, 818 S.W.2d 180, 183 (Tex. App.–Houston [1st Dist.] 1991, no writ) (finding that trial court granted leave to file late pleading where pleading was filed after deadline imposed by docket control order).

         Goswami directs us to presume the trial court granted leave to file a late pleading even if the filer did not ask for leave when: (1) the record does not reflect that the trial court did not consider the amended pleading; and (2) no surprise or prejudice is shown. Lee, 783 S.W.2d at 588; Goswami, 751 S.W.2d at 490; see Wilson v. Korthauer, 21 S.W.3d 573, 578 (Tex. App.–Houston [14th] 2000, pet. denied) (holding that resisting party did not prove surprise or prejudice because he did not secure ruling on motion to strike). We turn to an analysis of the Goswami presumption.

b. Goswami Analysis

(1) The Record Prong

         In determining if the record satisfies the first prong of the Goswami presumption, we consider: (1) whether the amended pleading was part of the record; and (2) whether the judgment either states that the trial court considered all the pleadings on file or is silent on the issue. Id. at 578 (citing Goswami, 751 S.W.2d at 490). If the answer to each of these questions is yes, the first prong of the test is met. Korthauer, 21 S.W.3d at 577 (citing Goswami, 751 S.W.2d at 490). Here, Brown's fourth amended petition was part of the record when the trial court granted Diamond Shamrock's motion for summary judgment. However, the judgment does not recite what the trial court considered before ruling. Consequently, while the record does not reflect that the trial court considered Brown's fourth amended petition, it also does not reflect that the trial court did not. We find that the first prong of the test for application of the Goswami presumption is satisfied. See Korthauer, 21 S.W.3d at 577.


(2) The "Surprise or Prejudice" Prong

         The second prong of the Goswami test focuses on the surprise or prejudice to the party opposing the filing of the amendment, including whether that party moved to strike the late-filed pleading. See id. Here, the record shows that Diamond Shamrock filed a response opposing Brown's motion for leave to file her fourth amended petition, alleging both surprise and prejudice flowing from the untimely filing. However, Diamond Shamrock did not file a motion to strike the pleading. When the resisting party files a motion to strike a late-filed amendment, Texas case law holds that absent a showing that the resisting party secured a ruling on the motion to strike, we presume, in accordance with Goswami, that the trial court considered the late-filed amendment. See Tex. R. App. P. 33.1; see also Korthauer, 21 S.W.3d at 578.

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Doris Brown v. Ultramar Diamond Shamrock Corp., Counsel Stack Legal Research, https://law.counselstack.com/opinion/doris-brown-v-ultramar-diamond-shamrock-corp-texapp-2004.