Francisco Herrera v. Sunbelt Rentals, Inc.

CourtCourt of Appeals of Texas
DecidedApril 9, 2024
Docket01-22-00793-CV
StatusPublished

This text of Francisco Herrera v. Sunbelt Rentals, Inc. (Francisco Herrera v. Sunbelt Rentals, Inc.) 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
Francisco Herrera v. Sunbelt Rentals, Inc., (Tex. Ct. App. 2024).

Opinion

Opinion issued April 9, 2024

In The

Court of Appeals For The

First District of Texas ———————————— NO. 01-22-00793-CV ——————————— FRANCISCO HERRERA, SR., Appellant V. SUNBELT RENTALS, INC., Appellee

On Appeal from the 281st District Court Harris County, Texas Trial Court Case No. 2022-29152

MEMORANDUM OPINION

Francisco Herrera, Sr. signed a contract to sell his real property to a third

party. During the sale process, he authorized the title company to pay Sunbelt

Rentals Inc. $170,877.75 to remove a lien Sunbelt had placed on his real property

following the entry of a default judgment against a “Francisco Herrera.” Francisco later filed suit against Sunbelt for declaratory judgment, unjust enrichment,

restitution, and money had and received claiming Sunbelt improperly filed a lien on

his real property to collect on a default judgment Sunbelt knew had not been entered

against him. Francisco alleged he authorized the payment to Sunbelt under duress

to save the sale and avoid breaching the sales contract.

Sunbelt filed a plea to the jurisdiction claiming that because Francisco had

authorized the payment and Sunbelt had released the lien on his property in

exchange, there was no live controversy between the parties and thus the trial lacked

jurisdiction. The trial court agreed. It granted Sunbelt’s plea holding Francisco’s

claims were moot and dismissing the case for lack of jurisdiction. Francisco argues

the trial court erred because (1) contrary to the court’s holding, there is a live

controversy over whether he is entitled to recover the money he paid Sunbelt to

remove Sunbelt’s invalid lien on his property, and (2) at most, his payment to

Sunbelt raises an affirmative defense to his claims, but does not deprive the court of

jurisdiction or render any of his claims moot. In the alternative, Francisco argues

the trial court’s order contains two errors and, to the extent the trial court treated

Sunbelt’s plea to the jurisdiction as a motion for summary judgment or a plea in bar,

it erred in doing so and in granting Sunbelt’s plea on that basis.

We reverse the trial court’s judgment and remand the case for further

proceedings.

2 Sunbelt’s Default Judgment Against “Francisco Herrera”

Francisco alleges that in 2017, his son, Francisco Herrera, Jr. (“Herrera, Jr.”),

rented equipment from Sunbelt. According to Francisco, Herrera, Jr. provided

Sunbelt with a copy of his driver’s license and “[p]ayments under the rental

agreement were made by” Herrera, Jr. The rental agreement, dated August 18, 2017,

was signed by “Francisco Herrera, Jr.” and contained Herrera, Jr.’s driver’s license

number. According to Francisco, Sunbelt and its attorneys had “actual knowledge

that the alleged agreement in question was with [his son] Francisco Herrera, Jr.

through their possession” of the rental agreement.

The equipment was damaged during Hurricane Harvey.1 Francisco alleges

that after the equipment was damaged, Sunbelt retained a collection agency to collect

payment from his son. On September 10, 2018, the collection agency “sent an email

to Francisco Herrera, Jr” at frankherrerajr@yahoo.com, and the “subject line [of the

email] identified Francisco Herrera, Jr. by the last four digits of his social security

number.” According to Francisco, Sunbelt “also made a negative credit report

against [his son] Francisco Herrera, Jr.”

1 We take judicial notice of the fact that Hurricane Harvey made landfall along the Texas coast on August 25, 2017.

3 On December 26, 2018, Sunbelt filed suit against a “Francisco Herrera” for

breach of contract and quantum meruit (“2018 Lawsuit”). 2 Sunbelt attached several

invoices to its petition reflecting the alleged amounts due for the equipment.

According to Francisco, Sunbelt’s suit arose “out of an alleged [equipment]

agreement that was purportedly between Defendant Sunbelt and [his son] Francisco

Herrera, Jr.” Francisco alleged he never had a “contract or agreement” with Sunbelt.

According to Francisco, the “account number” on the invoices attached to Sunbelt’s

petition matched his son’s “full driver’s license number, and the phone number on

those documents is Francisco Herrera, Jr.’s phone number.” Francisco alleges that

neither he nor Herrera, Jr was “personally served” with the 2018 Lawsuit and

“instead [Sunbelt] purportedly obtained substituted service.”

On July 29, 2019, the trial court signed a default judgment in favor of Sunbelt

against a “Francisco Herrera” in the 2018 Lawsuit. The trial court awarded Sunbelt

$170,877.75 in damages, attorney’s fees, and pre and post judgment interest.

Francisco alleges that Sunbelt’s 2018 Lawsuit never “indicate[d] that it was

against” him. According to Francisco,

The last four digits of the social security number referenced in the military service search that [Sunbelt] submitted [to the trial court in the 2018 Lawsuit] with [Sunbelt’s] motion for default judgment were 2624, but the last four digits of [his] social security number are 1390. Another affidavit submitted by [Sunbelt] in the [2018] Lawsuit referenced 2 The style of Sunbelt’s lawsuit was Sunbelt Rentals, Inc, v. Francisco Herrera, Cause No. 2018-90842, in the 281st Judicial District Court of Harris County, Texas.

4 communications with “Defendant” which were communications with Francisco Herrera, Jr.

Francisco alleges that even though Sunbelt knew “the last four digits of Francisco

Herrera, Jr.’s social security number,” his “driver’s license number,” and “his full

date of birth,” Sunbelt secured an abstract of judgment which falsely and in violation

of Section 52.003 of the Texas Property Code3 stated that the judgment debtor’s

social security number, driver’s license number, and date of birth were all

“UNKNOWN.”

Sunbelt filed the abstract of judgment in the Harris County real property

records in September 2019, placing a judgment lien on Francisco’s real property.

That same month, the trial court issued Sunbelt a writ of execution, allowing Sunbelt

to force the sale of Francisco’s property to satisfy the judgment. Sunbelt sent the

writ of execution to the Harris County Constable’s Office, but the Constable’s Office

was unable to serve “Francisco Herrera” with the writ of execution.

3 An abstract of judgment converts a money judgment into a judicial lien that may later be executed against real property to satisfy the judgment. TEX. PROP. CODE § 52.001 (noting properly recorded and indexed abstract of judgment creates lien on judgment debtor’s non-exempt real property in county); Bowman v. The Bank of New York Mellon Tr. Co., N.A., No. 05-13-01684-CV, 2016 WL 258765, at *3 (Tex. App.—Dallas Jan. 21, 2016, pet. denied) (mem. op.) (“An abstract of judgment . . . perfects a lien on property that is actually owned by the judgment debtor.”). Section 52.003 of the Property Code requires an abstract of judgment to contain, among other things, “the birthdate of the defendant, if available to the clerk or justice,” “the last three numbers of the driver’s license of the defendant, if available,” and “the last three numbers of the social security number of the defendant, if available.” TEX. PROP. CODE § 52.003(a)(2)–(4).

5 In October 2019, Sunbelt asked the Constable’s Office to place the “non

exempt real property on county auction sale.” The Constable’s Office spoke to the

“defendant” who informed the Constable’s Office that he was Herrera, Jr. and that

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

Related

Texas Department of Parks & Wildlife v. Miranda
133 S.W.3d 217 (Texas Supreme Court, 2004)
Peter C. Browning v. Jeff P. Prostok
165 S.W.3d 336 (Texas Supreme Court, 2005)
Dallas County Community College District v. Bolton
185 S.W.3d 868 (Texas Supreme Court, 2005)
Lowenberg v. City of Dallas
261 S.W.3d 54 (Texas Supreme Court, 2008)
Miga v. Jensen
299 S.W.3d 98 (Texas Supreme Court, 2009)
City of Elsa v. Gonzalez
325 S.W.3d 622 (Texas Supreme Court, 2010)
Miga v. Jensen
96 S.W.3d 207 (Texas Supreme Court, 2002)
Edwards v. Mid-Continent Office Distributors, L.P.
252 S.W.3d 833 (Court of Appeals of Texas, 2008)
Bland Independent School District v. Blue
34 S.W.3d 547 (Texas Supreme Court, 2000)
Edgington v. Maddison
870 S.W.2d 187 (Court of Appeals of Texas, 1994)
Martin v. DOSHOS I, LTD., INC.
2 S.W.3d 350 (Court of Appeals of Texas, 1999)
Dallas County Tax Collector v. Andolina
303 S.W.3d 926 (Court of Appeals of Texas, 2010)
Speaker v. Lawler
463 S.W.2d 741 (Court of Appeals of Texas, 1971)
Bonham State Bank v. Beadle
907 S.W.2d 465 (Texas Supreme Court, 1995)
Williams v. Lara
52 S.W.3d 171 (Texas Supreme Court, 2001)
Charvis v. Charvis
529 S.W.2d 814 (Court of Appeals of Texas, 1975)
Browning v. Placke
698 S.W.2d 362 (Texas Supreme Court, 1985)
Pennell v. United Insurance
243 S.W.2d 572 (Texas Supreme Court, 1951)

Cite This Page — Counsel Stack

Bluebook (online)
Francisco Herrera v. Sunbelt Rentals, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/francisco-herrera-v-sunbelt-rentals-inc-texapp-2024.