Gulf Coast Pros, LLC v. Monica Sweeney, Michael Sweeney, and Katie Sweeney-Scott

CourtCourt of Appeals of Texas
DecidedJune 20, 2024
Docket09-23-00320-CV
StatusPublished

This text of Gulf Coast Pros, LLC v. Monica Sweeney, Michael Sweeney, and Katie Sweeney-Scott (Gulf Coast Pros, LLC v. Monica Sweeney, Michael Sweeney, and Katie Sweeney-Scott) 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
Gulf Coast Pros, LLC v. Monica Sweeney, Michael Sweeney, and Katie Sweeney-Scott, (Tex. Ct. App. 2024).

Opinion

In The

Court of Appeals

Ninth District of Texas at Beaumont

__________________

NO. 09-23-00320-CV __________________

GULF COAST PROS, LLC, Appellant

V.

MONICA SWEENEY, MICHAEL SWEENEY, AND KATIE SWEENEY-SCOTT, Appellees

__________________________________________________________________

On Appeal from the County Court at Law No. 6 Montgomery County, Texas Trial Cause No. 23-04-05901-CV __________________________________________________________________

MEMORANDUM OPINION

In this accelerated appeal, Appellant/Cross-Appellee Gulf Coast Pros, LLC

(“GCP” or “Plaintiff”) appeals the trial court’s final judgment granting

Appellees/Cross-Appellants Monica Sweeney (“Monica”), Michael Sweeney

(“Michael”), and Katie Sweeney-Scott’s (“Katie”) (collectively “the Sweeneys” or

“Defendants”) Texas Citizen’s Participation Act (“TCPA”) motion to dismiss a

claim for breaching the non-disparagement and confidentiality terms of the parties’

1 settlement agreement, and the Sweeneys cross appeal from the trial court’s denial of

their request for attorney’s fees. See Tex. Civ. Prac. & Rem. Code Ann. § 27.008(b)

(an appeal from order on a TCPA motion to dismiss is an accelerated appeal); see

also Tex. Civ. Prac. & Rem. Code Ann. §§ 27.001-27.011 (the TCPA).1 As

explained below, we affirm the trial court’s judgment.

The TCPA Motions to Dismiss Under the TCPA

The TCPA provides that a party may file a motion to dismiss a legal action if

it is “based on or is in response to a party’s exercise of the right of free speech, right

to petition, or right of association or arises from any act of that party in furtherance

of the party’s communication or conduct described by Section 27.010(b)[.]” Tex.

Civ. Prac. & Rem. Code Ann. § 27.003(a). Section 27.005 of the TCPA provides as

follows, in relevant part:

(b) Except as provided by Subsection (c), on the motion of a party under Section 27.003, a court shall dismiss a legal action against the moving party if the moving party demonstrates that the legal action is based on or is in response to: (1) the party’s exercise of: (A) the right of free speech; (B) the right to petition; or (C) the right of association; or (2) the act of a party described by Section 27.010(b).

1 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. 2 (c) The court may not dismiss a legal action under this section if the party bringing the legal action establishes by clear and specific evidence a prima facie case for each essential element of the claim in question. (d) Notwithstanding the provisions of Subsection (c), the court shall dismiss a legal action against the moving party if the moving party establishes an affirmative defense or other grounds on which the moving party is entitled to judgment as a matter of law.

Id. at § 27.005(b)-(d).

Standard of Review

We review a trial court’s ruling on a TCPA motion to dismiss under a de novo

standard of review. Landry’s, Inc. v. Animal Legal Def. Fund, 631 S.W.3d 40, 45-

46 (Tex. 2021). Our de novo review includes a review to determine whether the

parties met their burdens of proof under the TCPA and whether a nonmovant has

presented clear and specific evidence establishing a prima facie case for each

essential element of the challenged claims. See id. We consider the pleadings and

affidavits stating the allegations upon which the claim or defense is based in the light

most favorable to the nonmovant. See Tex. Civ. Prac. & Rem. Code Ann. §

27.006(a); In re Lipsky, 460 S.W.3d 579, 586-87 (Tex. 2015); Push Start Indus.,

LLC v. Hous. Gulf Energy Corp., No. 09-19-00290-CV, 2020 Tex. App. LEXIS

9337, at *6 (Tex. App.—Beaumont Nov. 30, 2020, no pet.) (mem. op.) (citations

omitted). We consider evidence a court could consider under Rule 166a of the Texas

Rules of Civil Procedure. See Tex. Civ. Prac. & Rem. Code Ann. § 27.006(a).

3 Three-Step Process Under the TCPA

The TCPA provides a three-step process courts must follow in deciding

whether to dismiss a “legal action” to which the TCPA applies. Montelongo v.

Abrea, 622 S.W.3d 290, 295-96 (Tex. 2021). First, the defendant who has moved to

dismiss must demonstrate that the plaintiff’s claim “is based on or is in response to

[the movant]’s exercise of the right of free speech, right to petition, or right of

association or arises from any act of [the movant] in the furtherance of [the

movant]’s communication or conduct described by Section 27.010(b).” Tex. Civ.

Prac. & Rem. Code Ann. § 27.005(b) (internal formatting omitted); see also Tex.

Civ. Prac. & Rem. Code Ann. § 27.010(b).

Next, if the defendant meets its burden, the burden shifts to the plaintiff to

“‘establish[] by clear and specific evidence a prima facie case for each essential

element of the claim in question.’” ExxonMobil Pipeline Co. v. Coleman, 512

S.W.3d 895, 899 (Tex. 2017) (quoting Tex. Civ. Prac. & Rem. Code Ann. §

27.005(c)); see also Montelongo, 622 S.W.3d at 296. Finally, if the plaintiff makes

this showing, the court will dismiss the action if the defendant “establishes an

affirmative defense or other grounds on which the moving party is entitled to

judgment as a matter of law.” Tex. Civ. Prac. & Rem. Code Ann. § 27.005(d);

Montelongo, 622 S.W.3d at 296. Prima facie means “at first sight,” and under the

TCPA, a prima facie case is the “minimum quantum of evidence necessary to

4 support a rational inference that the allegation of fact is true.” USA Lending Grp.,

Inc. v. Winstead PC, 669 S.W.3d 195, 200 (Tex. 2023) (citing S&S Emergency

Training Sols., Inc. v. Elliott, 564 S.W.3d 843, 847 (Tex. 2018); Prima facie,

Garner’s Dictionary of Legal Usage (3d ed. 2011)). Evidence is “clear and specific”

if it provides enough detail to show the factual basis for the claim. Id. (citing In re

Lipsky, 460 S.W.3d at 590-91). Such evidence need not be conclusive,

uncontroverted, or found credible. Id. (citing In re Lipsky, 460 S.W.3d at 590).

On the third step of the analysis, we examine whether the defendants have

established that they are entitled to judgment as a matter of law on their affirmative

defenses. See Rogers v. Bryan, No. 09-21-00338-CV, 2023 Tex. App. LEXIS 505,

at *49 (Tex. App.—Beaumont Jan. 26, 2023, no pet.) (mem. op.). When determining

whether a party who seeks to dismiss the plaintiff’s case under the TCPA has met

its burden on this third step, we apply a standard of review essentially equivalent to

a motion for summary judgment on an affirmative defense. Id.; H-E-B, L.P. v.

Maverick Int’l, Ltd., No. 09-21-00311-CV, 2022 Tex App. LEXIS 7428, at *10 (Tex.

App.—Beaumont Oct. 6, 2022, pet. granted, judgm’t vacated w.r.m.) (mem. op.). 2

2 See also Rockman v. Ob Hospitalist Grp., Inc., No.

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