in Re Estate of Gloria Banuelos Martinez

CourtCourt of Appeals of Texas
DecidedApril 2, 2019
Docket01-18-00217-CV
StatusPublished

This text of in Re Estate of Gloria Banuelos Martinez (in Re Estate of Gloria Banuelos Martinez) 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
in Re Estate of Gloria Banuelos Martinez, (Tex. Ct. App. 2019).

Opinion

Opinion issued April 2, 2019

In The

Court of Appeals For The

First District of Texas ———————————— NO. 01-18-00217-CV ——————————— IN RE ESTATE OF GLORIA BANUELOS MARTINEZ

On Appeal from the County Court at Law No. 2 Fort Bend County, Texas Trial Court Case No. 13-CPR 026038

MEMORANDUM OPINION

This interlocutory appeal arises from a probate dispute. See TEX. CIV. PRAC.

& REM. CODE § 51.014(a)(1). The sole issue in this appeal is whether the trial court

properly appointed a receiver to sell real estate that was jointly owned by the estate

and one of the heirs. Because there is insufficient evidence to satisfy the statutory requirements for appointment of a receiver, we reverse the trial court’s order, and

we remand for further proceedings.

Background

In March 2004, Gloria Banuelos Martinez bought a house in Fort Bend

County with her daughter and son-in-law, Belinda and Thomas Kasmiersky. A

“Joint Ownership Agreement and Non-Testamentary Transfer Agreement” provided

that the property would be owned 50% by Belinda and Thomas, and 50% by Gloria,

who would be responsible for paying all ad valorem taxes and insurance. The

agreement established that upon Gloria’s death one-third of her one-half interest

would pass to Belinda in a non-testamentary transfer, and Belinda and Thomas

would have the option to purchase the remaining interest in the property at then-

current fair market value.

Gloria died intestate on August 4, 2013. She was survived by three children:

Belinda Kasmiersky, Yolanda Sanders, and Paul Martinez. No will was admitted to

probate, and the trial court appointed attorney Suzanne Kornblitt as dependent

administrator. Belinda sought reimbursement for ad valorem taxes paid during

Gloria’s lifetime. Belinda and Thomas also sought to buy the remaining interest in

the property.

For years, Gloria’s heirs have argued about the Fort Bend County property,

the estate’s most valuable asset. They have also disputed the validity of the non-

2 testamentary transfer agreement, Belinda’s claims for reimbursement, and the costs

of administration. Belinda and Yolanda have each filed declaratory judgment actions

seeking a determination of the validity and effect of the Joint Ownership Agreement

and Non-Testamentary Transfer Agreement. Belinda has maintained that, as a result

of the non-testamentary transfer, she owns a two-thirds interest in the property,1

whereas Yolanda has argued that the estate owns a one-half interest in the property

because the Agreement was invalid.

The trial court authorized the administrator to sell the entire property, and the

administrator and a third party entered into a sales contract, which required that the

closing date of the sale be on or before February 7, 2018.

The trial court confirmed the sale on February 5, 2018. Ten days later, the

administrator filed an amended application for sale of real property, which showed

the acreage associated with the property to be 1.8065 acres rather than 1.502 acres,

as indicated in the earnest money contract, the prior application for sale of real

property, and the prior order confirming the sale. On March 8, 2018, the trial court

vacated its February 5, 2018 decree confirming the sale of real property In its order,

the trial court indicated that the contract for sale of the property “terminated on

February 6, 2018 for many reasons, especially because albeit it has no effect on the

1 (⅓ of Gloria’s ½ interest) = ⅓ × ½ = ⅙; and ⅙ + ½ (Belinda & Thomas’s interest) = ⅙ + 3/6 = 4/6 = ⅔.

3 appraised value, the acreage reflected in the Application and Order to Sell and the

Report and Decree does not match the acreage shown on the deed records.”

Referencing the heirs’ contentious relationship, the administrator sought

appointment of a receiver to sell the property. She asserted that the heirs had orally

agreed to sell the house, but they disagreed about what amount of the sale proceeds

would be placed in the court’s registry. She contended that this had created a problem

for the title company and jeopardized the sale. In the application, the administrator

stated that there was “a sale pending for $180,000,” and the property was “in danger

of being lost, damaged, or materially injured” because there was a risk that “we may

lose the buyer.” The administrator also stated that the estate lacked the funds to pay

its debts, including insurance and property taxes. No evidence was attached to the

application, and although no reporter’s record was made of the hearing on the

application for appointment of a receiver, it is undisputed that no evidence was

presented at the hearing.

The trial court appointed a receiver to sell the entire property, deduct costs,

and disburse one-half of the proceeds to Belinda and one-half of the proceeds to the

registry of the court. Belinda then filed this interlocutory appeal.

Analysis

In her sole issue, Belinda argues that the trial court erred by granting the

administrator’s application for appointment of a receiver to sell the property. Among

4 other arguments, she contends that there was no evidence that the property was in

danger of being lost, damaged, or materially injured.

I. Evidentiary sufficiency is considered in an abuse-of-discretion review.

A party may bring an interlocutory appeal from an order appointing a receiver.

TEX. CIV. PRAC. & REM. CODE § 51.014(a)(1); see Estate of Hoskins, 501 S.W.3d

295, 301 (Tex. App.—Corpus Christi 2016, no pet.). We review an order appointing

a receiver for an abuse of discretion. Perry v. Perry, 512 S.W.3d 523, 526 (Tex.

App.—Houston [1st Dist.] 2016, no pet.); Benefield v. State, 266 S.W.3d 25, 31

(Tex. App.—Houston [1st Dist.] 2008, no pet.). “A trial court abuses its discretion

when it rules arbitrarily, unreasonably, without regard to guiding legal principles, or

without supporting evidence.” Bennett v. Baker Broocks & Lange, LLP, No. 01-13-

00674-CV, 2014 WL 3107661, at *1 (Tex. App.—Houston [1st Dist.] July 8, 2014,

no pet.) (mem. op.) (citing Bocquet v. Herring, 972 S.W.2d 19, 21 (Tex. 1998)).

Under the abuse-of-discretion standard, legal and factual sufficiency of the evidence

are not independent grounds of error: they are relevant factors in assessing whether

the trial court abused its discretion. See Fannin v. Fereday, No. 01-13-00951-CV,

2015 WL 4463694, at *3 (Tex. App.—Houston [1st Dist.] July 21, 2015, no pet.).

II. Chapter 64 provides the legal standard for appointment of a receiver over jointly owned property.

The party seeking the appointment of a receiver has the burden of proof to

demonstrate that the circumstances justify the appointment of a receiver. Benefield,

5 266 S.W.3d at 31. Texas Civil Practice and Remedies Code section 64.001 provides

that a “court of competent jurisdiction” may appoint a receiver in six specific

circumstances, including “(3) in an action between partners or others jointly owning

or interested in any property or fund . . . or (6) in any other case in which a receiver

may be appointed under the rules of equity.” TEX. CIV. PRAC. & REM. CODE

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