Harry L. Bowles v. State

CourtCourt of Appeals of Texas
DecidedAugust 17, 2006
Docket01-04-00801-CV
StatusPublished

This text of Harry L. Bowles v. State (Harry L. Bowles v. State) 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
Harry L. Bowles v. State, (Tex. Ct. App. 2006).

Opinion

Opinion issued August 17, 2006





In The

Court of Appeals

For The

First District of Texas





NO. 01-04-00801-CV





HARRY L. BOWLES, Appellant


V.


THE STATE OF TEXAS, Appellee





On Appeal from the 61st District Court

Harris County, Texas

Trial Court Cause No. 2002-44780





MEMORANDUM OPINION

          In this appeal, we consider whether appellant, Harry L. Bowles, has standing to seek a judgment declaring that sections 51.901 and 51.903 of the Texas Government Code and section 32.49 of the Texas Penal Code [collectively, “the Texas Lien Release Law”] are unconstitutional. We affirm the trial court’s judgment dismissing Bowles’s claims.

BACKGROUND

          The underlying declaratory judgment action is the latest in series of legal proceedings between Bowles and his former business partner, Charles N. Schwartz, Jr. As part of the ongoing business dispute, Bowles filed three liens against property owned by Schwartz in 1994. Schwartz filed a “Motion for Judicial Review of Documentation or Instrument Purporting to Create a Lien or Claim” pursuant to section 51.901 of the Texas Government Code, which was assigned to the 333rd District Court of Harris County. On August 9, 1998, the trial court issued findings of fact and conclusions of law, in which it found that “[t]here is no valid lien or claim created by this documentation or instrument.” It is not clear from the record whether Bowles appealed this August 9, 1998 ruling. Schwartz or his attorney, Grant Cook, notified Bowles of the trial court’s ruling and demanded that he remove the liens. Bowles refused to do so.

          In 1998 and 1999, the District Attorneys of Harris County, Grimes County, and Brazoria County demanded that Bowles release the liens within 21 days. Again, Bowles refused to do so. Bowles was then indicted in Harris County for “Refusing to Execute Release of Fraudulent Lien or Claim.” The indictment tracked the language of Texas Penal Code section 32.49 and provided as follows:

Harry Louis Bowles, hereafter styled the defendant, heretofore on or about May 26, 1998, did then and there unlawfully, with intent to defraud and harm another, own, hold, and was the beneficiary of a purported lien and claim asserted against real property and personal property that was fraudulent as described by Section 51.901(c) of the Texas Government Code, and did refuse to execute the release of the fraudulent lien and claim upon the request of Charles N. Schwarz, a person owning an interest in the property described in the document and instrument that is the basis of the lien and claim, after the expiration of twenty-one days following the date of receipt of actual notice from Charles N. Schwarz requesting the execution of a release of the fraudulent lien and claim.

          After a trial by jury, Bowles was convicted of the Class A misdemeanor offense. He served four days in jail and paid a $1000 fine. His conviction was affirmed by the Fourteenth Court of Appeals, and the Texas Court of Criminal Appeals refused to hear his petition for discretionary review. See Bowles v. State, No. 14-99-01396-CR, 2001 WL 1047026, *1 (Tex. App.—Houston [14th Dist.] Sept. 13, 2001, pet. ref’d) (not designated for publication).

          Bowles then filed his petition for declaratory judgment seeking to have the Lien Release Law declared unconstitutional. In a no-evidence motion for summary judgment, the State argued, among other grounds, that Bowles had no standing to bring his declaratory judgment. The trial court granted the State’s motion and dismissed Bowles’s claims. This appeal followed. 

PROPRIETY OF DISMISSAL

          In his first issue on appeal, Bowles argues that the trial court erred in granting the State’s no-evidence motion for summary judgment on the basis of standing. Standard of Review

          A no-evidence motion for summary judgment is essentially a directed verdict granted before trial, to which we apply a legal sufficiency standard of review. King Ranch, Inc. v. Chapman, 118 S.W.3d 742, 750-51 (Tex. 2003); Jackson v. Fiesta Mart, Inc., 979 S.W.2d 68, 70 (Tex. App.—Austin 1998, no pet.). In general, a party seeking a no-evidence summary judgment must assert that no evidence exists as to one or more of the essential elements of the non-movant’s claims on which it would have the burden of proof at trial. Holmstrom v. Lee, 26 S.W.3d 526, 530 (Tex. App.—Austin 2000, no pet.). Once the movant specifies the elements on which there is no evidence, the burden shifts to the non-movant to raise a fact issue on the challenged elements. See Tex. R. Civ. P. 166a(i). A no-evidence summary judgment will be sustained when (1) there is a complete absence of evidence of a vital fact, (2) the court is barred by rules of law or of evidence from giving weight to the only evidence offered to prove a vital fact, (3) the evidence offered to prove a vital fact is no more than a scintilla, or (4) the evidence conclusively establishes the opposite of a vital fact. King Ranch, 118 S.W.3d at 751. We view the evidence in the light most favorable to the non-movant, disregarding all contrary evidence and inferences. Id.

Standing

          In its no-evidence motion for summary judgment, the State argued that standing, i.e., a justiciable case or controversy, was an essential element of a declaratory judgment, see Bonham State Bank v. Beadle, 907 S.W.2d 465, 467 (Tex. 1995), and that Bowles had produced no evidence that he possessed such standing. Bowles’s response to the motion, to which he attached his own affidavit, asserted that he had standing based on three facts: (1) that he had been convicted under the Texas Lien Release Law; (2) that he was subject to further prosecution under the Texas Lien Release Law; and (3) that the underlying dispute—the reason that Bowles filed the liens—is ongoing. We will address each basis upon which Bowles claims standing.

          Bowles’s Conviction

          Bowles argues that he has standing to challenge the Lien Release Law because he has been criminally convicted thereunder.

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

Related

Holmstrom v. Lee
26 S.W.3d 526 (Court of Appeals of Texas, 2000)
Ex Parte Crosley
548 S.W.2d 409 (Court of Criminal Appeals of Texas, 1977)
Tatum v. State
846 S.W.2d 324 (Court of Criminal Appeals of Texas, 1993)
McCormick v. Texas Commerce Bank National Ass'n
751 S.W.2d 887 (Court of Appeals of Texas, 1988)
Dallas County District Attorney v. Doe
969 S.W.2d 537 (Court of Appeals of Texas, 1998)
Passel v. Fort Worth Independent School District
440 S.W.2d 61 (Texas Supreme Court, 1969)
Bonham State Bank v. Beadle
907 S.W.2d 465 (Texas Supreme Court, 1995)
King Ranch, Inc. v. Chapman
118 S.W.3d 742 (Texas Supreme Court, 2003)
Jackson v. Fiesta Mart, Inc.
979 S.W.2d 68 (Court of Appeals of Texas, 1998)
State v. Morales
869 S.W.2d 941 (Texas Supreme Court, 1994)

Cite This Page — Counsel Stack

Bluebook (online)
Harry L. Bowles v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/harry-l-bowles-v-state-texapp-2006.