Home Buyers Warranty Corporation, Builders Structural Services, Inc., II and National Home Insurance Company v. Brian M. Hand and Evelyn Howard-Hand

CourtCourt of Appeals of Texas
DecidedMay 26, 1993
Docket03-92-00033-CV
StatusPublished

This text of Home Buyers Warranty Corporation, Builders Structural Services, Inc., II and National Home Insurance Company v. Brian M. Hand and Evelyn Howard-Hand (Home Buyers Warranty Corporation, Builders Structural Services, Inc., II and National Home Insurance Company v. Brian M. Hand and Evelyn Howard-Hand) 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.

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Home Buyers Warranty Corporation, Builders Structural Services, Inc., II and National Home Insurance Company v. Brian M. Hand and Evelyn Howard-Hand, (Tex. Ct. App. 1993).

Opinion

HOME BUYERS V HAND
IN THE COURT OF APPEALS, THIRD DISTRICT OF TEXAS,


AT AUSTIN




NO. 3-92-033-CV


HOME BUYERS WARRANTY CORPORATION, BUILDERS STRUCTURAL
SERVICES, INC., II, AND NATIONAL HOME INSURANCE COMPANY,


APPELLANTS



vs.


BRIAN M. HAND AND EVELYN HOWARD-HAND,


APPELLEES





FROM THE DISTRICT COURT OF TRAVIS COUNTY, 345TH JUDICIAL DISTRICT


NO. 476,720, HONORABLE J. NEIL DANIEL, JUDGE PRESIDING




Appellees Brian M. Hand and Evelyn Howard-Hand (the Hands) brought suit against appellants Home Buyers Warranty Corporation, Builders Structural Services, Inc. II, and National Home Insurance Company (collectively, "Home Buyers") for breach of an express warranty, breach of the duty of good faith and fair dealing, and deceptive trade practices. After a jury trial, the district court rendered judgment in favor of the Hands. Home Buyers brings six points of error. We will affirm the judgment.



BACKGROUND

Austin JS Corporation ("Austin JS"), a construction company, built a new house for the Hands. The Hands received a booklet from Home Buyers informing them that as buyers from Austin JS, they automatically obtained a warranty wherein Home Buyers promised to repair certain construction defects to the house if Austin JS was unable to do so first. The Hands soon noticed that most of the windows and the garage roof leaked during wet weather. They notified Austin JS of this problem, but it did not repair the defects. The Hands then filed a claim with Home Buyers, which sent out adjusters and hired a contractor, Austin Imperial Construction, Inc. ("Austin Imperial"), to repair the Hands' house. (1) The leaks reappeared after the attempted repairs, however, and the Hands notified Home Buyers of this situation. Home Buyers refused to pay for further repairs, and the Hands subsequently brought this action in district court.



GOOD FAITH

Home Buyers' first point of error complains about the trial court's failure to submit its requested jury issue inquiring whether Home Buyers had acted in good faith when it attempted to repair the Hands' home. Home Buyers asserts such an issue is required under the Residential Construction Liability Act ("the Act"). (2)

Section 27.002 of the Act provides, "This chapter applies to any action to recover damages resulting from a construction defect." Section 27.001(2) defines "construction defect" as "a matter concerning the design, construction, or repair of a new residence . . . on which a person has a complaint against a contractor." A "contractor" is "a person contracting with an owner for the construction or sale of a new residence constructed by that person or . . . repair of a new and existing residence." Act § 27.001(3). The Act governs claims involving the quality of residential construction that homeowners previously had brought under theories of negligence, express warranty of construction of such quality, implied warranty of good and workmanlike construction, and deceptive or unconscionable conduct under the Texas Deceptive Trade Practices--Consumer Protection Act ("DTPA"). (3) See John T. Montford, Will G. Barber, & Robert L. Duncan, 1989 Texas DTPA Reform, 21 St. Mary's L. J. 525, 575 (1990).

The Hands have not sued Home Buyers for damages relating to the quality of the original construction of their home or Austin Imperial's attempted repairs; instead, they sued for breach of an express warranty that defects in their home would be repaired. (4) The Act applies only to damages resulting from construction defects, which are not at issue in this case.

Even assuming Home Buyers is a "contractor" under the Act, it was not entitled to its requested jury instruction on good faith. We first note that Home Buyers cannot be considered a contractor in relation to the original home constructed by Austin JS. Section 7(D) of Home Buyers' warranty booklet states, "This warranty is independent of the contractual arrangement between the Homebuyer and the Builder for the construction of the Home." Therefore, Home Buyers could only be a contractor if Austin Imperial was its agent for purposes of the attempted repairs of the Hands' house.

Assuming the Hands were suing Home Buyers over the quality of Austin Imperial's repairs, they were required to give written notice of the construction defects. Act § 27.004(a). (5) Home Buyers could then make a settlement offer detailing repairs to correct the construction defects and subsequently perform these repairs. Act § 27.004(b). Section 27.004(f) of the Act provides, "If suit is filed after a contractor makes repairs as provided by this section, the claimant may not be awarded damages . . . unless the trier of fact finds that the attempt to repair was not made in good faith." (emphasis added). Home Buyers argues this provision required the trial court to submit its jury question on good faith. However, section 27.004(f) only applies when the contractor makes repairs after the homeowner notifies him that his previous work was defective. In this case, neither Austin Imperial nor any other company performed any repairs after the Hands notified Home Buyers that Austin Imperial's work was defective. Nor did Home Buyers make any settlement offer. Section 27.004(e) of the Act expressly provides that defenses such as the good faith exception do not apply if "a contractor fails to make an offer . . . [or] fails to repair the defects. . . ." Home Buyers thus cannot rely upon any good faith defense. We overrule the first point of error.



SPECIAL RELATIONSHIP

Home Buyers' second point of error contends that there was legally and factually insufficient evidence to support the jury's answer that a special relationship existed between Home Buyers and the Hands. It does not challenge the submission of the issue.

In deciding a legal-sufficiency or "no evidence" point, we must consider only the evidence and inferences tending to support the finding of the trier of fact and disregard all evidence and inferences to the contrary. Alm v. Aluminum Co. of Am., 717 S.W.2d 588, 593 (Tex. 1986), cert. denied, 111 S.Ct. 135 (1990); Garza v. Alviar, 395 S.W.2d 821, 823 (Tex. 1965). When determining a factual-sufficiency challenge, we must consider and weigh all the evidence and should set aside the judgment only if it is so contrary to the overwhelming weight of the evidence as to be clearly wrong and unjust. Cain v. Bain, 709 S.W.2d 175, 176 (Tex. 1986); see generally William Powers, Jr. & Jack Ratliff, Another Look at "No Evidence" and "Insufficient Evidence," 69 Tex. L. Rev. 515 (1991).

The trial court's question on a special relationship between the parties contained this instruction:



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Home Buyers Warranty Corporation, Builders Structural Services, Inc., II and National Home Insurance Company v. Brian M. Hand and Evelyn Howard-Hand, Counsel Stack Legal Research, https://law.counselstack.com/opinion/home-buyers-warranty-corporation-builders-structur-texapp-1993.