H2ECO Bulk, LLC v. Bill Brinkmeyer and Sheri Brinkmeyer

CourtCourt of Appeals of Texas
DecidedJuly 30, 2025
Docket04-24-00184-CV
StatusPublished

This text of H2ECO Bulk, LLC v. Bill Brinkmeyer and Sheri Brinkmeyer (H2ECO Bulk, LLC v. Bill Brinkmeyer and Sheri Brinkmeyer) 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
H2ECO Bulk, LLC v. Bill Brinkmeyer and Sheri Brinkmeyer, (Tex. Ct. App. 2025).

Opinion

Fourth Court of Appeals San Antonio, Texas

MEMORANDUM OPINION No. 04-24-00184-CV

H2ECO BULK, LLC, Appellant

v.

Bill BRINKMEYER and Sheri Brinkmeyer, Appellees

From the County Court at Law, Gillespie County, Texas Trial Court No. 16914-CCV Honorable Christopher Nevins, Judge Presiding

Opinion by: Lori Massey Brissette, Justice

Sitting: Irene Rios, Justice Lori Massey Brissette, Justice H. Todd McCray, Justice

Delivered and Filed: July 30, 2025

REVERSED AND REMANDED

H2Eco Bulk, LLC appeals a judgment entered after a jury trial. After reviewing the parties’

briefs and the trial court record, and after considering oral argument, we reverse the trial court’s

judgment and remand for a new trial because the evidence at trial was legally insufficient to support

the damages awarded. 04-24-00184-CV

BACKGROUND

In June of 2021, the Brinkmeyers sought to replaster their pool. They were told by a plaster

company that they would have to drain the pool, have it replastered, and then immediately fill it

with water to allow the plaster to cure properly without cracking. Because the timing of the water

delivery was crucial to the success of the project, first the plaster company and then the

Brinkmeyers reached out to H2Eco by phone to discuss the project and the importance of the

delivery date. Having been assured that H2Eco had experience in such projects and understood the

importance of the delivery date, the Brinkmeyers agreed to contract with H2Eco for the water

delivery, agreeing on the amount of water needed, the price, and the delivery date before paying

for the delivery over the phone.

Subsequently, H2Eco sent an email confirmation to the Brinkmeyers, confirming the date

of delivery, the price, and the amount of water to be delivered, but also including the following

additional statement: “While we cannot guarantee times, our driver will call 1 hour before arriving

on site.” Similar language was included in a separate invoice email sent by H2Eco, within a three-

page attachment entitled “Terms and Conditions.” 1 The Brinkmeyers never replied, as they

testified they did not read the emails until after delivery.

As planned, the Brinkmeyers drained their pool and had it replastered. They then waited

for the water delivery. When H2Eco did not arrive as scheduled, the Brinkmeyers and their plaster

company reached out several times to H2Eco inquiring of the whereabouts of the delivery truck

and were told the driver was on his way. But, the truck did not arrive that day.

1 Notably, H2Eco did not assert, in the trial court or on appeal, that any other provision of the emailed terms and conditions apply, including an arbitration clause, a disclaimer, and a limitation of damages provision.

-2- 04-24-00184-CV

In an attempt to forestall cracking, the Brinkmeyers started a slow stream of water from

their well into the pool and allowed it to run all night. 2 The driver finally arrived the following

day, late in the afternoon, explaining that the driver did not have access to a fuel card necessary

for the drive. By then, the plaster on the sides of the pool had cracked. The plaster at the bottom

of the pool, which had been covered by the overnight water flow, had not cracked.

The Brinkmeyers sued H2Eco for breach of contract, fraud, fraudulent inducement, and

violations of the Texas Deceptive Trade Practices Act. The only witnesses to testify were the

Brinkmeyers, Susan and Louis Tessie – the owner and employee of the company that performed

the plaster work, and a sales and operations employee of H2Eco. The parties agreed to bifurcate

the trial and have the attorneys’ fees submitted to the court post-verdict. The jury returned a verdict

finding that the emailed terms and conditions were not part of the parties’ agreement, that H2Eco

failed to comply with the agreement to deliver the water on the agreed delivery date, and that its

failure to do so was not excused. The jury further found that H2Eco fraudulently induced the

Brinkmeyers into entering into the agreement for water delivery, that H2Eco engaged in a false,

misleading, or deceptive act or practice that the Brinkmeyers relied on to their detriment and which

was the producing cause of damages, but that such deceptive act or practice was not engaged in

knowingly. Finally, the jury found the Brinkmeyers’ own negligence contributed to or caused their

own damages, apportioning 30% of the responsibility to the Brinkmeyers.

The jury answered three questions as to damages. First, the jury found that, as a result of

H2Eco’s breach of contract, the Brinkmeyers suffered $14,900 in past damages and $500 in future

damages. As a result of H2Eco’s fraudulent inducement, the jury found the Brinkmeyers suffered

2 The Brinkmeyers did not turn the water on completely to fill the pool for the very reason that they ordered the water delivery in the first place, to avoid burning out their well—their only source of water for their home.

-3- 04-24-00184-CV

$15,000 in past damages and $20,000 in future damages. And, the jury found that, as a result of

H2Eco’s deceptive act or practice, the Brinkmeyers suffered $15,000 in past damages and $20,000

in future damages. The trial court entered a final judgment awarding the Brinkmeyers $51,800.00

in actual damages, $2,621.36 in expenses and costs, and $64,265.15 in attorneys’ fees. 3 The trial

court also awarded an additional $15,000.00 in fees in the event of appeal.

DISCUSSION

On appeal, H2Eco contends the trial court erred by submitting the case to the jury without

expert evidence supporting causation, by submitting the breach of contract claim to the jury, and

by submitting a question to the jury as to whether the emailed terms and conditions constituted

part of the agreement. H2Eco, further, contends the trial court erred in denying H2Eco’s motion

for a directed verdict as to the fraudulent-inducement and DTPA claims. Finally, H2Eco contends

the damages findings are unsupported by the record.

Sufficiency of the Evidence as to Causation

First, H2Eco contends the Brinkmeyers were required to bring expert testimony to prove

causation, specifically that the failure to immediately fill the pool with water caused the cracking.

Whether expert testimony is necessary to prove causation is a question of law to be reviewed de

novo. FFE Transp. Servs., Inc. v. Fulgham, 154 S.W.3d 84, 89–90 (Tex. 2004); Mack Trucks, Inc.

v. Tamez, 206 S.W.3d 572, 583 (Tex. 2006).

In so reviewing, we should determine whether the lay testimony provided is any evidence

to support causation, using the standard appropriate to a legal sufficiency challenge. Seitel Data

Ltd. v. Simmons, 362 S.W.3d 782, 785 (Tex. App.—Texarkana 2012, no pet.). A legal sufficiency

challenge “will be sustained when (a) there is a complete absence of evidence of a vital fact, (b)

3 The record is not clear as to how the trial court arrived at the final damages amount, but we surmise that it represents some sort of an aggregation of the jury damage findings and some application of the proportionate responsibility.

-4- 04-24-00184-CV

the court is barred from rules of law or of evidence from giving weight to the only evidence offered

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