Enterprise v. Harris County

CourtCourt of Appeals of Texas
DecidedMarch 17, 2011
Docket01-09-00271-CV
StatusPublished

This text of Enterprise v. Harris County (Enterprise v. Harris County) 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
Enterprise v. Harris County, (Tex. Ct. App. 2011).

Opinion

Opinion issued March 17, 2011

In The

Court of Appeals

For The

First District of Texas

————————————

NO. 01-09-00271-CV

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Enterprise Leasing Company of Houston, Appellant

V.

Harris County Toll Road Authority, Appellee

On Appeal from the County Civil Court at Law No. 4

Harris County, Texas

Trial Court Case No. 915,718

O P I N I O N

          In this appeal, we consider whether the trial court erred in affirming an administrative ruling holding appellant, Enterprise Leasing Company of Houston [“Enterprise”] liable to the Harris County Toll Road Authority [“HCTRA”] for tolls that were incurred, but not paid for, by lessees of Enterprise’s vehicles.  Specifically, we consider (1) whether Enterprise was entitled to trial de novo in the trial court, (2) whether Enterprise established the affirmative defenses of estoppel and waiver, and (3) whether HCTRA’s selective enforcement of the applicable statute precludes it from pursuing its claims against Enterprise.  We affirm.

BACKGROUND

          Enterprise is a rental car agency that leases cars to consumers.  Occasionally, some renters of Enterprise’s vehicles drive on HCTRA’s toll roads without paying the required toll.  The operator’s failure to pay a required toll on a Texas roadway violates section 284.070 of the Texas Transportation Code, which provides as follows:

A person commits an offense if the person:

(1) operates a vehicle on a county project; and

(2) fails or refuses to pay a toll imposed under Section 284.069

Tex. Transp. Code Ann. § 284.070 (Vernon 2009).    The transportation code provides that that “[i]n the event of an offense committed under Section 284.070 . . . the registered owner of the nonpaying vehicle is liable for the payment of both the proper toll and an administrative cost.” Tex. Transp. Code Ann. § 284.0701(a).  The statute further provides that the registered owner of a vehicle for which the proper toll was not paid also commits an offense if he fails to make payment after receiving proper notice of nonpayment. See Tex. Transp. Code Ann. § 284.0701(c). Thus, under these sections, Enterprise, as registered owner of the nonpaying cars, would be liable for the tolls, even though their renters actually committed the offense.

            However, in September 2003, the Texas Legislature created an affirmative defense for car companies whose renters incurred toll road violations.  The statute creating this affirmative defense provides as follows:

It is an exception to the application of Subsection (a) or (c) if the registered owner of the vehicle is a lessor of the vehicle and not later than the 30th day after the date the notice of nonpayment is mailed provides to the authority:

(1) a copy of the rental, lease, or other contract document covering the vehicle on the date of the nonpayment under Section 284.070, with the name and address of the lessee clearly legible; or

(2) electronic data, other than a photocopy or scan of a rental or lease contract, that contains the information required . . . covering the vehicle on the date of the nonpayment under Section 284.070.

Tex. Transp. Code Ann. § 284.0701(d).  After the affirmative defense statute providing the exception for rental companies was passed, Enterprise and HCTRA entered into an agreement that settled all offenses for which Enterprise may have been liable that occurred prior to the effective date of the affirmative defense statute.

            After the affirmative offense statute went into effect, Enterprise began claiming the exception for new violations.  Specifically, as Enterprise would get notices of nonpayment from HCTRA, it would look up the renter’s information and provide it to HCTRA.

            Enterprise and HCTRA initially cooperated to create an electronic exchange system to eliminate the vast amount of paperwork that was involved in the reporting process.  However, Enterprise was unable to keep up with the influx of unpaid invoices and soon it fell behind in its efforts to claim the exception created by section 284.0701(d) by submitting copies of the rental agreements within 30 days.

            Steve Moore, a representative of Enterprise, called HCTRA’s attorney, D’Arwyn Daniels, to explain the difficulty that Enterprise was having in providing the rental agreements within 30 days of notice of nonpayment.  Enterprise claims that Daniels told it that the 30-day requirement could be extended to 45-days for all future reporting purposes.

            In November 2006, Daniels requested a meeting with Enterprise, at which he advised Enterprise that HCTRA expected Enterprise to pay fines and fees for hundreds of violations that accrued after July 7, 2004, because Enterprise had not properly proved that it was entitled to claim the statutory exemption provided by section 284.  Specifically, Enterprise had provided the rental information required to claim the exemption more than 30 days after it had received notice of nonpayment.

            In December 2007, seven of HCTRA’s claims were heard in an administrative hearing to determine whether Enterprise was liable for the alleged violations by its renters, or whether it was entitled to claim the statutory exemption.  The administrative judge determined that Enterprise was liable for the tolls, and ordered it to pay administrative fees and the tolls to HCTRA.  Enterprise appealed the decision to Harris County Court at Law No. 4, and the trial court affirmed five of the seven claims. 

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Enterprise v. Harris County, Counsel Stack Legal Research, https://law.counselstack.com/opinion/enterprise-v-harris-county-texapp-2011.