Elijah W. Ratcliff, Individually and Elijah W. Ratcliff v. Polk County Title, Inc., Ronald P. Boyce and E.L. McClendon, Jr.

CourtCourt of Appeals of Texas
DecidedAugust 31, 2004
Docket09-04-00124-CV
StatusPublished

This text of Elijah W. Ratcliff, Individually and Elijah W. Ratcliff v. Polk County Title, Inc., Ronald P. Boyce and E.L. McClendon, Jr. (Elijah W. Ratcliff, Individually and Elijah W. Ratcliff v. Polk County Title, Inc., Ronald P. Boyce and E.L. McClendon, Jr.) 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
Elijah W. Ratcliff, Individually and Elijah W. Ratcliff v. Polk County Title, Inc., Ronald P. Boyce and E.L. McClendon, Jr., (Tex. Ct. App. 2004).

Opinion

In The



Court of Appeals



Ninth District of Texas at Beaumont



____________________



NO. 09-04-124 CV



ELIJAH W. RATCLIFF, Appellant



V.



POLK COUNTY TITLE, INC., RONALD P. BOYCE,

AND E.L. McCLENDON, JR., Appellees



On Appeal from the 411th District Court

Polk County, Texas

Trial Cause No. 19256



MEMORANDUM OPINION (1)

This is an appeal by the plaintiff in a defamation suit against a title company, a title examiner, and an attorney for disseminating a title report that expressed the opinion that the plaintiff's grandmother had died intestate. We affirm the judgment for the reasons explained in this opinion.

Allegedly acting in both an individual capacity and as the executor of the estate of Katie Ratcliff, Elijah W. Ratcliff filed a suit in which he alleged that the appellees, Polk County Title, Inc., Ronald P. Boyce, and E.L. McClendon, Jr., published a title report which stated that "Elijah Ratcliff and wife, Katie Ratcliff acquired title to subject property by deed dated May 24, 1913. It appears that they both died intestate." (2) Ratcliff alleged that Katie Ratcliff died testate, that the title report was therefore defamatory, and that publication of the allegedly defamatory statement injured him in negotiating a timber contract and in conducting a bail bonding business. Ratcliff also alleged that the injury followed a pattern of disregard for the rights of property owners and the civil rights of "Negro citizens."

Ratcliff originally filed the suit in federal court and commenced the state court litigation after the federal court suit was dismissed for lack of subject matter jurisdiction. In its unpublished opinion, the federal district court noted that, although Ratcliff had filed an application to probate the will of Katie Ratcliff, the will had never been presented for action in court. The court reasoned that until a court order admits the will to probate, Katie Ratcliff did die intestate. Therefore, the court reasoned, the statement is true and no defamation occurred. Ratcliff appealed to the Fifth Circuit. The appellate court ruled in an unpublished opinion that Ratcliff had neither stated a cause of action for defamation nor established that his complaint rests on a cognizable constitutional violation, and dismissed the appeal as frivolous. When Ratcliff filed suit in state court, the defendants filed a motion to dismiss due to issue preclusion arising from a dismissal of federal court litigation over identical issues between the same parties. The defendants raised issue preclusion in a motion for summary judgment. The motion for summary judgment also moved for dismissal on the grounds that no defamation occurred as a matter of law. In their motion, the defendants asserted that the plaintiff produced no evidence of publication of a defamatory statement, and no evidence that the will had been admitted to probate at the time of publication or that the statement caused damage to the plaintiff. Ratcliff moved for summary judgment on liability. The trial court dismissed the suit with prejudice. Ratcliff presents seven issues in his appeal.

In issue one, the appellant contends that he properly invoked the trial court's jurisdiction in his first supplemental petition. In his argument under this point of error, Ratcliff contends that the district court and the county court maintain concurrent jurisdiction to hear a suit such as the one that he filed, and that the trial court therefore erred to the extent it relied upon jurisdictional grounds. Apparently, no action was ever taken on the application for probate filed in the county court at law after Katie Ratcliff's death in 1968. The appellant seems to argue that the district court has concurrent jurisdiction with the probate court, but he fails to address the suit that the appellant himself claims is "pending and viable" in the county court at law. At any rate, issue one has no merit because the trial court did not dismiss Ratcliff's suit for lack of jurisdiction. Issue one is overruled.

Issue two contends that the appellant was duly named executor of the estate of Katie Ratcliff, and that the appellees somehow violated his civil rights by encroaching upon that status through publication of the title report. In his argument under this point of error, Ratcliff blames the failure to admit the will to probate upon racial prejudice of county officials. Although he admits the will was not admitted for probate, Ratcliff asserts that he was named executor. The appellant seems to argue that the appellees violated federal civil rights statutes by publishing a title report that did not recognize Ratcliff's status as executor. The federal district court held that Ratcliff's federal civil rights claims were frivolous. On appeal, the Fifth Circuit ruled that Ratcliff had neither stated a cause of action for defamation nor established that his complaint rests upon a cognizable violation, and dismissed the appeal as frivolous. Thus, the federal civil rights claims were adjudicated in federal court and cannot be re-litigated in state court. See Acree v. Air Line Pilots Ass'n, 390 F.2d 199, 202-03 (5th Cir. 1968), cert. denied, 393 U.S. 852, 89 S.Ct. 88, 21 L.Ed.2d 122 (1968) (The dismissal of a federal suit is conclusive as to all matters that were actually adjudged in determining that the court lacked jurisdiction.). Although the federal court left the door open for the appellant to pursue a suit in state court, he certainly cannot maintain a suit for violation of the federal civil rights statutes upon facts that the federal court found did not support an action in federal court.

In the argument supporting his second issue, the appellant goes on to contend that his motion for summary judgment established that Ratcliff was a licensed attorney in 1962. Ratcliff attached documents to his motion to the effect that, although he was convicted of felony theft in 1973 and disbarred in 1974, the criminal conviction was tainted by racial prejudice in jury selection and his own incompetence when he represented himself in the criminal trial. On appeal he argues the trial court should have accepted the affidavit he offered in support of the plaintiff's motion for summary judgment. The "Affidavit of Veracity" merely states that the facts recited in the body of the motion are true and correct. Motions for summary judgment and responses to motions for summary judgment do not constitute summary judgment evidence, even when verified. Nicholson v. Memorial Hosp. Sys., 722 S.W.2d 746, 748-49 (Tex.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

John A. Acree v. Air Line Pilots Association
390 F.2d 199 (Fifth Circuit, 1968)
Musser v. Smith Protective Services, Inc.
723 S.W.2d 653 (Texas Supreme Court, 1987)
Mustang Athletic Corp. v. Monroe
137 S.W.3d 336 (Court of Appeals of Texas, 2004)
Karen Corp. v. Burlington Northern & Santa Fe Railway Co.
107 S.W.3d 118 (Court of Appeals of Texas, 2003)
Nicholson v. Memorial Hospital System
722 S.W.2d 746 (Court of Appeals of Texas, 1986)
McIlvain v. Jacobs
794 S.W.2d 14 (Texas Supreme Court, 1990)
Crown Coat Front Co. v. United States
393 U.S. 853 (Supreme Court, 1968)

Cite This Page — Counsel Stack

Bluebook (online)
Elijah W. Ratcliff, Individually and Elijah W. Ratcliff v. Polk County Title, Inc., Ronald P. Boyce and E.L. McClendon, Jr., Counsel Stack Legal Research, https://law.counselstack.com/opinion/elijah-w-ratcliff-individually-and-elijah-w-ratcli-texapp-2004.