Gail Rigsby v. Eecu

CourtCourt of Appeals of Texas
DecidedApril 2, 2015
Docket02-14-00074-CV
StatusPublished

This text of Gail Rigsby v. Eecu (Gail Rigsby v. Eecu) 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
Gail Rigsby v. Eecu, (Tex. Ct. App. 2015).

Opinion

COURT OF APPEALS SECOND DISTRICT OF TEXAS FORT WORTH

NO. 02-14-00074-CV

GAIL RIGSBY APPELLANT AND APPELLEE

V.

EECU APPELLEE AND APPELLANT

----------

FROM THE 236TH DISTRICT COURT OF TARRANT COUNTY TRIAL COURT NO. 236-265926-13

MEMORANDUM OPINION1

Appellant and Cross-Appellee Gail Rigsby appeals the trial court’s

judgment granting Appellee and Cross-Appellant EECU’s motion to dismiss filed

pursuant to the Texas Citizens’ Participation Act (TCPA). See Tex. Civ. Prac. &

Rem. Code Ann. § 27.005 (West 2015). EECU appeals the same judgment,

1 See Tex. R. App. P. 47.4. arguing that the trial court should have granted part of the motion to dismiss on

different grounds. We will affirm in part and reverse and remand in part.

EECU is a member-owned Texas financial institution that offers its

products and services to individuals who live or work in several north Texas

counties. Rigsby began working for EECU in 2005. In 2012, she occupied the

position of Branch Relationship Manager for EECU’s Arlington branch.

On May 11, 2012, members of EECU’s executive team interviewed Rigsby

as part of an internal investigation involving irregularities with one of the financial

products that it offers at its Arlington branch—the “First-Time Car Buyer

Program.” Several days later, on May 15, 2012, EECU terminated Rigsby’s

employment.

Rigsby filed her original petition against EECU on May 15, 2013. Claiming

that EECU had accused her of (i) engaging in fraud in regard to the car-buyer

program, (ii) violating federal law (the Graham-Leach Bliley Act), and (iii) failing to

protect sensitive client information, Rigsby alleged claims against EECU for

defamation, intentional infliction of emotional distress, negligence, and gross

negligence and sought exemplary damages. EECU generally denied Rigsby’s

allegations, pleaded affirmative defenses, and filed a motion to dismiss the

claims under the TCPA. EECU’s motion to dismiss argued that each of Rigsby’s

claims were based on, related to, or were in response to EECU’s exercise of its

right to free speech; that Rigsby could not establish by clear and specific

evidence a prima facie case for the elements of each claim; and that EECU had

2 established a valid defense—statute of limitations—to the defamation claim. The

trial court granted EECU’s motion to dismiss, finding “that [Rigsby’s] claims are

time-barred by the applicable Statute of Limitations.”

In her first issue, Rigsby argues that the trial court erroneously dismissed

her defamation claim as time-barred because she filed it timely and did not

unreasonably delay serving EECU. EECU responds that the trial court properly

dismissed Rigsby’s defamation claim because she did not exercise diligence in

effecting service. We limit our analysis to whether Rigsby diligently served

EECU.

The legislature enacted the TCPA “to encourage and safeguard the

constitutional rights of persons to petition, speak freely, associate freely, and

otherwise participate in government to the maximum extent permitted by law and,

at the same time, protect the rights of a person to file meritorious lawsuits for

demonstrable injury.” Tex. Civ. Prac. & Rem. Code Ann. § 27.002 (West 2015).

To achieve these ends, the legislature provided that if a legal action is brought in

response to a party’s exercise of the right of free speech, the right to petition, or

the right of association, that person may move to dismiss the action.

Id. § 27.003(a) (West 2015). The movant bears the initial burden to show by a

preponderance of the evidence that the action “is based on, relates to, or is in

response to the party’s exercise” of any of the aforementioned constitutional

rights. Id. § 27.005(b). If the movant satisfies this burden, the trial court must

dismiss the legal action unless the party who brought the action “establishes by

3 clear and specific evidence a prima facie case for each essential element of the

claim in question.” Id. § 27.005(b), (c). Notwithstanding whether the previous

burden is met, the trial court shall dismiss a legal action against the moving party

if the moving party establishes by a preponderance of the evidence each

essential element of a valid defense to the nonmovant’s claim. Id. § 27.005(d).

The trial court found that Rigsby’s defamation claim was barred by

limitations, as affirmatively pleaded by EECU; the trial court therefore determined

that EECU met its burden under section 27.005(d). See id. We review the trial

court’s ruling de novo. See United Food & Commercial Workers Int’l Union v.

Wal-Mart Stores, Inc., 430 S.W.3d 508, 511 (Tex. App.—Fort Worth 2014, no

pet.).

To “bring suit” for defamation within the one-year limitations period

prescribed by civil practice and remedies code section 16.002(a), a plaintiff must

not only file suit within the applicable limitations period, she must also use

diligence to have the defendant served with process. Tex. Civ. Prac. & Rem.

Code Ann. § 16.002(a) (West 2002); see Gant v. DeLeon, 786 S.W.2d 259, 260

(Tex. 1990); Slagle v. Prickett, 345 S.W.3d 693, 696‒97 (Tex. App.—El Paso

2011, no pet.). When a plaintiff files a petition within the limitations period but

does not serve the defendant until after the statutory period has expired, the date

of service relates back to the date of filing if the plaintiff exercised diligence in

effecting service. Gant, 786 S.W.2d at 260.

4 When a defendant has affirmatively pleaded the defense of limitations and

shown that service was obtained after limitations expired, the burden shifts to the

plaintiff to explain the delay. Proulx v. Wells, 235 S.W.3d 213, 216 (Tex. 2007)

(reasoning that plaintiff must present evidence of efforts she made to serve the

defendant and explain every lapse in effort or period of delay). In assessing

diligence, the relevant inquiry is whether the plaintiff acted as an ordinarily

prudent person would have acted under the same or similar circumstances and

was diligent in effecting service up until the time the defendant was served. Id. If

no excuse is offered for a delay, lack of diligence will be found as a matter of law.

Gant, 786 S.W.2d at 260; James v. Gruma Corp., 129 S.W.3d 755, 759‒60 (Tex.

App.—Fort Worth 2004, pet. denied).

The record demonstrates that Rigsby filed her original petition on May 15,

2013, and that citation issued the next day. Rigsby served EECU’s President

with the petition three months later, on August 14, 2013, but the service was

improper because the President was not EECU’s registered agent for service.

On September 9, 2013, EECU notified Rigsby of the error by letter, and on

November 4, 2013, the parties filed a joint motion to quash the citation served on

EECU’s President. On November 8, 2013, the trial court granted the motion to

quash and ordered that EECU be served as of November 8, 2013.

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Related

Proulx v. Wells
235 S.W.3d 213 (Texas Supreme Court, 2007)
Ashley v. Hawkins
293 S.W.3d 175 (Texas Supreme Court, 2009)
Boyattia v. Hinojosa
18 S.W.3d 729 (Court of Appeals of Texas, 2000)
James v. Gruma Corp.
129 S.W.3d 755 (Court of Appeals of Texas, 2004)
Holt v. D'Hanis State Bank
993 S.W.2d 237 (Court of Appeals of Texas, 1999)
Gant v. DeLeon
786 S.W.2d 259 (Texas Supreme Court, 1990)
Slagle v. Prickett
345 S.W.3d 693 (Court of Appeals of Texas, 2011)

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