Imelda Cardoza and Fernando Cardoza v. Reliant Energy, HL&P

CourtCourt of Appeals of Texas
DecidedMay 20, 2005
Docket01-03-01126-CV
StatusPublished

This text of Imelda Cardoza and Fernando Cardoza v. Reliant Energy, HL&P (Imelda Cardoza and Fernando Cardoza v. Reliant Energy, HL&P) 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
Imelda Cardoza and Fernando Cardoza v. Reliant Energy, HL&P, (Tex. Ct. App. 2005).

Opinion

Opinion issued May 20, 2005





In The

Court of Appeals

For The

First District of Texas





NO. 01-03-01126-CV





IMELDA CARDOZA AND FERNANDO CARDOZA, Appellants


v.


RELIANT ENERGY HL&P, Appellee





On Appeal from the 80th District Court

Harris County, Texas

Trial Court Cause No. 2001-24857





MEMORANDUM OPINION


          Appellants, Imelda and Fernando Cardoza, appeal from a take-nothing judgment rendered in favor of appellee, Reliant Energy HL&P (“Reliant”). We determine whether the trial court erred in denying the Cardozas’ request for an irrebuttable spoliation-presumption instruction, in granting Reliant’s summary judgment motion, and in rendering a take-nothing judgment against the Cardozas. We affirm.

Facts


          On May 24, 2000, a fire severely damaged the Cardozas’ home and personal property. The Cardozas’ homeowners insurer, Farmers Insurance Exchange (“Farmers”), brought a subrogation action against Reliant for breach of contract, breach of warranty, and negligence for allegedly improperly installing, maintaining, servicing, designing, and inspecting the equipment bringing electricity into the home. Farmers sought damages for the amounts paid under the policy (including repair, replacement, and cleaning costs for the home and its contents and the cost of the Cardozas’ living expenses during the home’s repair), the costs of Farmers’s investigation to determine the cause and origin of the fire, and attorney’s fees.

          A few months later, the Cardozas intervened, also asserting claims against Reliant for breach of contract, breach of warranty, and negligence. They sought recovery of “damages suffered as a result of [Reliant’s] conduct,” including repair and replacement costs for their real and personal property, but also sought mental-anguish damages and lost wages, as well as attorney’s fees incurred by their own counsel. In later briefing filed with the trial court, the Cardozas described the damages that they sought as “damages not covered by their homeowners insurance.”

          The Cardozas then moved the trial court for a spoliation instruction because, during the fire, Reliant had removed part of the power line running from its pole to the home (“the drop line”) and destroyed the drop line soon thereafter. Specifically, the Cardozas prayed that the court (1) give the jury a spoliation instruction “that it is presumed that had the drop line been produced, it would have revealed cause and origin findings [for the fire] unfavorable to Reliant” and also that the court (2) prevent Reliant from rebutting this spoliation presumption. The trial court denied the motion.

          A few months after the trial court’s spoliation ruling, Reliant moved for no-evidence summary judgment “on the claims of interveners Fernando and Imelda Cardoza” on the grounds that no evidence of breach or proximate cause existed. See Tex. R. Civ. P. 166a(i). In response, the Cardozas re-urged their spoliation motion and attached evidence relevant to spoliation, implicitly acknowledging—as they do on appeal—that a spoliation presumption was the only way for them to provide evidence of breach and causation and thus to defeat the summary judgment motion. The trial court at first denied Reliant’s summary judgment motion, but, upon Reliant’s motion for reconsideration, the court granted the motion to reconsider, granted Reliant’s summary judgment motion, and rendered judgment that the Cardozas take nothing “on all of their claims,” which the court then dismissed with prejudice. Spoliation

          Under their sole issue, the Cardozas first argue that the trial court erred in denying their request for a spoliation-presumption instruction.

A.      Standard of Review 


           Trial courts have broad discretion in taking measures to address spoliation of evidence. See Wal-Mart Stores, Inc. v. Johnson, 106 S.W.3d 718, 721 (Tex. 2003); Trevino v. Ortega, 969 S.W.2d 950, 953 (Tex. 1998). A trial court abuses its discretion by acting arbitrarily, unreasonably, or without consideration of guiding principles. Downer v. Aquamarine Operators, Inc., 701 S.W.2d 238, 241-42 (Tex. 1985). A trial court generally does not abuse its discretion when it bases its decision on conflicting evidence. Davis v. Huey, 571 S.W.2d 859, 862 (Tex. 1978).

B.     The Law Concerning Spoliation 


          Spoliation is the improper destruction of evidence relevant to a case. Malone v. Foster, 956 S.W.2d 573, 577 (Tex. App.—Dallas 1997), aff’d on other grounds, 977 S.W.2d 562 (Tex. 1998).

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Related

Trevino v. Ortega
969 S.W.2d 950 (Texas Supreme Court, 1998)
Malone v. Foster
956 S.W.2d 573 (Court of Appeals of Texas, 1997)
Wal-Mart Stores, Inc. v. Johnson
106 S.W.3d 718 (Texas Supreme Court, 2003)
Offshore Pipelines, Inc. v. Schooley
984 S.W.2d 654 (Court of Appeals of Texas, 1999)
Downer v. Aquamarine Operators, Inc.
701 S.W.2d 238 (Texas Supreme Court, 1985)
Davis v. Huey
571 S.W.2d 859 (Texas Supreme Court, 1978)

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Imelda Cardoza and Fernando Cardoza v. Reliant Energy, HL&P, Counsel Stack Legal Research, https://law.counselstack.com/opinion/imelda-cardoza-and-fernando-cardoza-v-reliant-ener-texapp-2005.