Harris County, Texas v. Inter Nos, Ltd.

CourtCourt of Appeals of Texas
DecidedMay 4, 2006
Docket01-04-00736-CV
StatusPublished

This text of Harris County, Texas v. Inter Nos, Ltd. (Harris County, Texas v. Inter Nos, Ltd.) 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
Harris County, Texas v. Inter Nos, Ltd., (Tex. Ct. App. 2006).

Opinion

Opinion issued May 4, 2006





In The

Court of Appeals

For The

First District of Texas





NO. 01-04-00736-CV





HARRIS COUNTY, TEXAS, Appellant


V.


INTER NOS, LTD., Appellee





On Appeal from County Court at Law No. 3

Harris County, Texas

Trial Court Cause No. 745,619





O P I N I O N

          Appellant, Harris County, Texas (“the County”), challenges the trial court’s judgment in favor of appellee, Inter Nos, Ltd. In two issues, the County contends that the trial court abused its discretion by (1) excluding, from the jury’s consideration, evidence that Union Pacific Railroad Company had not abandoned a railroad easement on property condemned by the County and (2) preventing the cross-examination of Inter Nos’s expert witness regarding whether the railroad easement had been abandoned. We affirm the judgment of the trial court.

Factual Background

          The County filed a statutory condemnation suit to take a portion of a tract of land, owned by Inter Nos, for the construction of the Westpark Toll Road. The taking was effectuated, and the sole issue to be tried to the jury was damages—the calculation of the market value of the property on the date of the taking.  

          Before the taking, the northern part of the condemned property was encumbered by a 100-foot-wide common carrier, freight rail easement owned by Southern Pacific Railroad. Southern Pacific later merged into Union Pacific. Union Pacific subsequently filed an application with the Surface Transportation Board (“STB”) seeking authority to abandon its easement on Inter Nos’s property. The STB granted Union Pacific’s application and, in its decision, imposed certain conditions governing the abandonment of the easement. One of the conditions concerned potential future negotiations between Union Pacific and the Metropolitan Transit Authority (“Metro”) for a use agreement regarding the easement. The STB decision provided that Union Pacific could fully abandon the easement if no use agreement with Metro was reached by May 7, 2001—the 180th day after STB’s decision. Although no use agreement was ever reached between Metro and Union Pacific regarding the easement, it is undisputed that the County condemned the property before the expiration of the 180-day negotiation period.  

          Before trial, Inter Nos served the County with requests for disclosure under Rule 194.2 of the Texas Rules of Civil Procedure. Tex. R. Civ. P. 194.2. In one of these requests, Inter Nos specifically asked the County to disclose the amount and its method of calculating damages in this case. See Tex. R. Civ. P. 194.2(d). In its response, the County referred Inter Nos to its appraiser’s expert reports for this information, stating, in pertinent part, that the “[f]air market value of property condemned is determined by appraiser’s opinions and appraisal reports.” In responses to Inter Nos’s request for disclosure under rule 194.2(f)(2) and (3), the County identified Gerald Teel as the County’s testifying appraisal expert and stated that a report setting forth the basis for his opinions as to value would be forthcoming.

          The County filed two sets of supplemental discovery responses with reports by Gerald Teel, regarding the value of the property on the date that it was condemned. In both reports, Teel states that the County’s calculation of damages in this action was based on the assumption that the railroad easement had been abandoned as of the date of the taking. Specifically, Teel testified that his calculation of the property’s value was based on the assumption that the northern part of the Inter Nos property was “part of [an] abandoned railroad corridor” and was “owned in fee and [] unencumbered by any easements.” (Emphasis added.) Teel further states that:

[T]he subject property was previously part of a railroad corridor. The railroad company had an easement on the property. It is our assumption the easement has been abandoned upon the sale of the corridor to METRO and Harris County. The site is being valued as an unencumbered parcel of land.


(Emphasis added.) Teel’s reports were not amended, and the County never supplemented its response to Inter Nos’s request for disclosure under rule 194.2(d).

Following these reports and discovery responses, Inter Nos filed the report of its appraisal expert, David Lewis, who also calculated the value of the property based on the assumption that the land was not encumbered by any easement.

          Teel, the County’s expert, was deposed three days before the trial, and he testified, for the first time, that, contrary to his expert reports, the County’s theory of damages and calculation of the condemned property’s value at trial would be based on the assumption that the easement had not been abandoned as of the date of the taking. Teel testified that, the day before his deposition was taken, he had been instructed by the County’s counsel to make this new assumption. Teel further testified that the existence of the easement diminished the market value of the condemned property.

          Three days later at the pretrial hearing, Inter Nos objected to the qualifications of Teel to testify as an expert in this case on the grounds that he used improper methodology to determine the condemned property’s value, and the objection was sustained. Inter Nos further objected to the admission of any evidence that Union Pacific had not abandoned the easement. Inter Nos argued that the exclusion of this evidence was warranted because the County failed to supplement its discovery responses and expert reports to put Inter Nos on notice that it was proceeding at trial with a theory and calculation of damages different from what was stated in its discovery responses. It further argued that the admission of this evidence would constitute unfair prejudice and surprise. The trial court sustained the objection, and the trial commenced.

          During trial, the County attempted to admit into evidence three exhibits and the testimony of Teel as a “fact witness,” which it argued established that the easement had not been abandoned as of the date of the taking. During Inter Nos’s case in chief, the County also attempted to cross-examine Inter Nos’s value expert, David Lewis, regarding whether the railroad easement had been abandoned as of the date of the taking.

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Bluebook (online)
Harris County, Texas v. Inter Nos, Ltd., Counsel Stack Legal Research, https://law.counselstack.com/opinion/harris-county-texas-v-inter-nos-ltd-texapp-2006.