in Re: MHI Partnership, LTD.

CourtCourt of Appeals of Texas
DecidedMay 29, 2008
Docket14-07-00851-CV
StatusPublished

This text of in Re: MHI Partnership, LTD. (in Re: MHI Partnership, 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
in Re: MHI Partnership, LTD., (Tex. Ct. App. 2008).

Opinion

Memorandum Opinion Issued April 23, 2008 Withdrawn; Motion for Rehearing Denied; Petition for Writ of Mandamus Conditionally Granted; and Memorandum Opinion filed May 29, 2008

Memorandum Opinion Issued April 23, 2008 Withdrawn; Motion for Rehearing Denied; Petition for Writ of Mandamus Conditionally Granted; and Memorandum Opinion filed May 29, 2008.

In The

Fourteenth Court of Appeals

____________

NO. 14-07-00851-CV

IN RE MHI PARTNERSHIP, LTD., Relator

ORIGINAL PROCEEDING

WRIT OF MANDAMUS

M E M O R A N D U M   O P I N I O N  ON  REHEARING

Real parties= in interest motion for rehearing is denied.  The memorandum opinion issued on April 23, 2008 is withdrawn.  This memorandum opinion is substituted in its place.

Relator MHI Partnership, Ltd. seeks a writ of mandamus directing the presiding judge of the 11th District Court of Harris County, Texas, to vacate an order denying MHI=s motion to compel arbitration.  We conditionally grant the writ. 

                                                                                    Background

MHI is a homebuilder that does business as Pioneer Homes and Plantation Homes.  Real parties in interest are 30 owners of 18 homes purchased in the Villages of Bear Creek subdivision in Katy, Texas between June 2002 and September 2004.  They sued MHI for damages or rescission of their home purchases contending that MHI failed to disclose alleged contamination of their homes= water supply. 

MHI used three different earnest money contract forms during the relevant time period.  Two homes were purchased using Form 1 (the oldest form); twelve homes were purchased using Form 2 (an intermediate form); and four homes were purchased using Form 3 (the most recent form).  While the three contract forms contain some differences, those differences are not material to the disposition of this proceeding.  Each earnest money contract signed by the homeowners includes an arbitration provision. 

On August 15, 2005, MHI moved to compel arbitration and to stay the trial court proceedings.  The homeowners opposed arbitration; among other things, they contended that the arbitration provisions in their earnest money contracts are procedurally and substantively unconscionable, and were procured by fraud.  The trial court gave the parties a year to conduct discovery regarding enforceability of the arbitration provisions.  Following discovery and briefing, the trial court held a hearing on the motions to compel on August 7, 2007.[1]  The trial court orally denied the motion at the hearing=s conclusion.[2] 


                                                       Standard of Review

The arbitration provisions at issue here recite that they are governed by the Federal Arbitration Act (AFAA@), 9 U.S.C. '' 1B16.  The homeowners do not dispute this point.  Mandamus is the appropriate vehicle to seek relief from a trial court order denying a motion to compel arbitration under the FAA.  In re Bank One, N.A., 216 S.W.3d 825, 826 (Tex. 2007) (orig. proceeding) (per curiam).  To obtain mandamus relief, the relator must demonstrate that (1) the trial court clearly abused its discretion; and (2) there is no adequate remedy by appeal.  In re Sw. Bell Tele. Co., 226 S.W.3d 400, 403 (Tex. 2007) (orig. proceeding).  The trial court abuses its discretion if it reaches a decision that constitutes a clear and prejudicial error of law.  Walker v. Packer, 827 S.W.2d 833, 839 (Tex. 1992) (orig. proceeding).  As to factual matters, the relator must establish that the trial court could have reached only one decision.  Id. at 840.

The party seeking to compel arbitration under the FAA must establish that (1) a valid arbitration agreement exists, and (2) the claims at issue fall within that agreement=s scope.  In re Dillard Dep=t Stores, Inc., 186 S.W.3d 514, 515 (Tex. 2006) (orig. proceeding) (per curiam).  The homeowners= challenges to arbitration in this case focus solely on validity.  The trial court=s determination of an arbitration agreement=s validity is a legal question.  Id.


Contentions that arbitration provisions are invalid because they are procedurally and substantively unconscionable must be assessed against the backdrop of the strong policy favoring arbitration under federal and state law.  See, e.g., Cantella & Co. v. Goodwin, 924 S.W.2d 943, 944 (Tex. 1996) (orig. proceeding) (per curiam) (citing Moses H. Cone Mem=l Hosp. v. Mercury Constr. Co., 460 U.S. 1, 24B25 (1983); Prudential Secs., Inc. v. Marshall, 909 S.W.2d 896, 898 (Tex. 1995) (orig. proceeding) (per curiam); Capital Income Props.‑LXXX v. Blackmon, 843 S.W.2d 22, 23 (Tex. 1992) (orig. proceeding) (per curiam); Jack B. Anglin Co. v. Tipps, 842 S.W.2d 266, 268 (Tex. 1992) (orig. proceeding)); see also TMI, Inc. v. Brooks, 225 S.W.3d 783, 792 (Tex. App.CHouston [14th Dist.] 2007, pet. denied) (op. on reh=g).  ABecause the law favors arbitration, the party opposing arbitration bears the burden to prove unconscionability.@  TMI, Inc., 225 S.W.3d at 792 (citing In re FirstMerit Bank, 52 S.W.3d 749, 756 (Tex. 2001) (orig. proceeding)).  This allocation comports with the policy animating the FAA, which is Amotivated, first and foremost, by a congressional desire to enforce agreements into which parties ha[ve] entered.@  Dean Witter Reynolds, Inc. v. Byrd, 470 U.S. 213, 220 (1985); see also Hall Street Assocs., L.L.C. v. Mattel, Inc., __ U.S. __, 128 S. Ct. 1396, 1402 (2008) (ACongress enacted the FAA to replace judicial indisposition to arbitration with a

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

Related

American Heritage Life Insurance v. Orr
294 F.3d 702 (Fifth Circuit, 2002)
Dean Witter Reynolds Inc. v. Byrd
470 U.S. 213 (Supreme Court, 1985)
Green Tree Financial Corp.-Alabama v. Randolph
531 U.S. 79 (Supreme Court, 2000)
Buckeye Check Cashing, Inc. v. Cardegna
546 U.S. 440 (Supreme Court, 2006)
Hall Street Associates, L. L. C. v. Mattel, Inc.
552 U.S. 576 (Supreme Court, 2008)
In Re AdvancePCS Health L.P.
172 S.W.3d 603 (Texas Supreme Court, 2005)
In Re Palm Harbor Homes, Inc.
195 S.W.3d 672 (Texas Supreme Court, 2006)
In Re Bank One, N.A.
216 S.W.3d 825 (Texas Supreme Court, 2007)
In Re Southwestern Bell Telephone Co., LP
226 S.W.3d 400 (Texas Supreme Court, 2007)
In Re U.S. Home Corp.
236 S.W.3d 761 (Texas Supreme Court, 2007)
Haase v. Glazner
62 S.W.3d 795 (Texas Supreme Court, 2002)
In Re Luna
175 S.W.3d 315 (Court of Appeals of Texas, 2004)
In Re Bill Heard Chevrolet, Ltd.
209 S.W.3d 311 (Court of Appeals of Texas, 2006)
Olshan Foundation Repair Co. v. Ayala
180 S.W.3d 212 (Court of Appeals of Texas, 2005)
Ernst & Young, L.L.P. v. Pacific Mutual Life Insurance Co.
51 S.W.3d 573 (Texas Supreme Court, 2001)
NABORS DRILLING USA, LP v. Carpenter
198 S.W.3d 240 (Court of Appeals of Texas, 2006)
EZ Pawn Corp. v. Mancias
934 S.W.2d 87 (Texas Supreme Court, 1996)
Pony Express Courier Corp. v. Morris
921 S.W.2d 817 (Court of Appeals of Texas, 1996)
Brown v. Aztec Rig Equipment, Inc.
921 S.W.2d 835 (Court of Appeals of Texas, 1996)

Cite This Page — Counsel Stack

Bluebook (online)
in Re: MHI Partnership, LTD., Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-mhi-partnership-ltd-texapp-2008.