Floating Bulk Terminal, L.L. and Econo-Rail Corporation v. Coal Logistics Corporation, J. Patrick Dowd and Lillian Moore Dowd

CourtCourt of Appeals of Texas
DecidedJuly 25, 2002
Docket14-01-00055-CV
StatusPublished

This text of Floating Bulk Terminal, L.L. and Econo-Rail Corporation v. Coal Logistics Corporation, J. Patrick Dowd and Lillian Moore Dowd (Floating Bulk Terminal, L.L. and Econo-Rail Corporation v. Coal Logistics Corporation, J. Patrick Dowd and Lillian Moore Dowd) 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
Floating Bulk Terminal, L.L. and Econo-Rail Corporation v. Coal Logistics Corporation, J. Patrick Dowd and Lillian Moore Dowd, (Tex. Ct. App. 2002).

Opinion

Reversed and Rendered and Opinion filed July 25, 2002

Reversed and Rendered and Opinion filed July 25, 2002.

In The

Fourteenth Court of Appeals

____________

Nos. 14-01-00055-CV

FLOATING BULK TERMINAL, L.L.C. and ECONO-RAIL CORPORATION, Appellants/Cross-Appellees

V.

COAL LOGISTICS CORPORATION, J. PATRICK DOWD, and

LILLIAN MOORE DOWD, Appellees/Cross-Appellants

On Appeal from the 61st District Court

Harris County, Texas

Trial Court Cause No. 98-08965

O P I N I O N


A jury found that Econo-Rail Corporation breached an agreement to own a ship jointly with Coal Logistics Corporation.[1]  It awarded $70,000 in past damages and $2,000,000 in future damages on the breach of contract claim.  The jury also found that Econo-Rail breached a fiduciary duty to Coal Logistics, but did not enter a damages finding on this claim.  However, the jury did award attorneys’ fees.  The trial court rendered judgment on the verdict, awarded pre- and post-judgment interest on the past damages, post-judgment interest on the future damages, and attorneys’ fees.  We reverse and render judgment that Coal Logistics take nothing because we conclude there is no evidence the parties agreed on the essential terms necessary to create an enforceable contract.

FACTUAL AND PROCEDURAL BACKGROUND

In October 1997, Patrick Dowd, president of Coal Logistics, learned of an opportunity to buy a self-unloading cargo vessel.  On October 17, Dowd executed a memorandum of agreement to purchase the ship for $2.1 million.  But, the agreement required a 10 percent deposit within five banking days (by October 24).  Payment in full was due at the time of delivery, expected to be between November 17 and November 21, 1997.  If Dowd did not pay the purchase price as provided in the agreement, the sellers had the right to cancel the agreement; the deposit, together with interest earned, would be released to the sellers.

Dowd approached William (“Bill”) Scott about joint investment and co-ownership.  Bill and his brother controlled a group of companies, among them Beaumont Bulk Terminals, Inc. (“BBT”), and Econo-Rail.[2]

Dowd and Bill Scott met in Texas on October 22.  The next evening, Dowd drafted a contract, which provided in part:

1) [Coal Logistics] hereby assigns all its rights and obligations under the Vessel Purchase Contract to the BBT Group.

2) In consideration, a 33 percent interest in the new vessel[-]owning company shall be granted to [Coal Logistics].  Said minority interest shall be deemed to have been earned upon [Coal Logistics]’s payment of our one-third of the $210,000 (US) cash payment due on October 24th as the initial ten percent down payment under the Vessel Purchase Contract.


Dowd’s proposed contract also contained a buy-out provision that would have allowed BBT, between July and December of 1998, to acquire Coal Logistics’s 33 percent interest for what appears to be $500,000.

On October 24, Coal Logistics assigned BBT its interest in the memorandum agreement.  The $210,000 was also deposited, with Coal Logistics contributing $70,000.

The same day, the parties began to disagree about the terms of their agreement.  BBT’s attorney, Craig Cavalier, drafted an agreement modifying the terms in Dowd=s proposed draft.  Cavalier’s draft provided the following in part:

1.         [Coal Logistics] has assigned all it’s [sic] rights and obligations under The Vessel Purchase Contract to The BBT Group.  The BBT Group through a wholly owned subsidiary (hereafter “Newco”) . . . will acquire title to the vessel free and clear of all liens, claims and encumbrances.

2.         In consideration of the foregoing, [Coal Logistics] will acquire a 33 percent interest in Newco subject to the terms and conditions set forth herein.  Said minority interest shall be earned upon [Coal Logistics]’s payment of one third (a) of the $210,000 (US) cash payment due on October 24 as the initial ten percent down payment under the Vessel Purchase Contract and [Coal Logistics]’s execution of those documents necessary to evidence its proportionate responsibility for the financed portion of the purchase price and other anticipated costs associated with putting the vessel back in service.  (Emphasis added.) 

Cavalier’s draft also reduced the buy-out option to $200,000.

Four days later, Dowd returned a marked-up copy of the Cavalier draft.  Dowd marked out the language requiring Coal Logistics to pay for its proportionate share of the purchase price and the refitting costs.  The revamped draft contract looked like this:


Said minority interest shall be earned upon [Coal Logistics]’s payment of one third (a) of the $210,000 (US) cash payment due on October 24 as the initial ten percent down payment under the Vessel Purchase Contract and [Coal Logistic]’s execution of those documents necessary to effect purchase of the vessel.

Dowd also deleted a portion requiring joint responsibility for insurance and added a provision requiring BBT to provide insurance.  The buy-out amount was changed from $200,000 to $300,000.

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Floating Bulk Terminal, L.L. and Econo-Rail Corporation v. Coal Logistics Corporation, J. Patrick Dowd and Lillian Moore Dowd, Counsel Stack Legal Research, https://law.counselstack.com/opinion/floating-bulk-terminal-ll-and-econo-rail-corporati-texapp-2002.