in Re SAM-Construction Services, LLC

CourtCourt of Appeals of Texas
DecidedDecember 22, 2022
Docket09-22-00363-CV
StatusPublished

This text of in Re SAM-Construction Services, LLC (in Re SAM-Construction Services, LLC) 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 SAM-Construction Services, LLC, (Tex. Ct. App. 2022).

Opinion

In The

Court of Appeals

Ninth District of Texas at Beaumont

__________________

NO. 09-22-00363-CV __________________

IN RE SAM-CONSTRUCTION SERVICES, LLC

__________________________________________________________________

Original Proceeding 163rd District Court of Orange County, Texas Trial Cause No. B190455-C __________________________________________________________________

MEMORANDUM OPINION

In a petition for a writ of mandamus, Relator SAM-Construction Services,

LLC (“SAM”) argues that the trial court abused its discretion by disposing of SAM’s

motion to dismiss without addressing the merits of SAM’s motion, which asserted

that the plaintiff failed to attach a certificate of merit pursuant to Chapter 150 of the

Texas Civil Practice and Remedies Code in her first filed pleading against SAM.

SAM argues the trial court’s refusal to rule on the merits of SAM’s motion deprives

SAM of an adequate remedy by appeal. The Real Party in Interest, Maricela Salazar-

Linares, individually and as representative of the Estate of Martin Linares-Segura

1 (“Linares”), argues SAM cannot establish it lacks an adequate remedy by appeal

because SAM failed to perfect a timely accelerated appeal. She further argues the

trial court correctly denied SAM’s motion to dismiss because her claims arise out of

errors or omissions in construction, inspection and safety services rather than

professional engineering services. We conditionally grant mandamus relief.

Trial Court Proceedings

In 2019 Linares asserted wrongful death and survival claims against South

Texas Illumination, LLC, Flex Supply, Inc., and Third Coast Services, LLC. She

alleged her husband, Martin Linares-Segura, was electrocuted and killed while

working as a construction employee when a side-boom tractor hoisting a light pole

contacted overhead powerlines. In 2021 Linares amended her petition to add

wrongful death and survival claims against SAM-Construction Services, LLC, SAM

Construction LLC, SAM, LLC and SAM Construction and Investment, Inc. The

pleadings regarding SAM state, in relevant part:

19. At all relevant times, Defendant Sam Construction Services LLC, Sam Construction LLC, Sam, LLC, and Sam Construction and Investment (collectively referred to as “SAM”) was hired to inspect the illumination project being performed by all Defendants. According to its website, SAM “provide[s] construction services solutions, including contract administration, construction engineering and inspection, observation, quality assurance and quality management, and the development of quality manuals and specifications”-which, upon information and belief, it was hired to do and/or purported to do in this accident. SAM, according to its website, “supports clients and contractors by putting clear processes in place to keep communication open and maintain project schedules and budgets” and “ensures clients 2 receive the foundational data and management support they need to successfully complete construction work”-which, upon information and belief, it was hired to do and/or purported to do in this accident. Moreover, SAM claims it “provides construction teams around the nation the construction engineering and inspection oversight they need to keep projects compliant, on time, and on budget. . . . [o]ur program managers are already familiar with your state and local requirements . . . [and] work with contractors, consultants, trades, and vendors to keep communication open, maintain project controls, and set clear expectations for quality and performance”-which, based upon information and belief, it was hired to do and/or purported to do in this accident.

Linares alleged SAM’s negligence caused the fatal incident, as follows:

26. The death of decedent was caused solely and wholly through the negligence of defendants, in that Defendant, Sam Construction Services LLC, and its servants, agents, and employees were grossly negligent, careless, and reckless in that they failed and neglected to properly park the sideboom tractor or crane, failed and neglected to have the side- boom tractor or crane under proper control, and failed to obtain or maintain the necessary licensure, permits or certifications to operate said side-boom tractor or crane. SAM was further negligent, inter alia, in the following: (1) Providing construction services solutions, including contract administration, construction engineering and inspection, observation, quality assurance and quality management, and the development of quality manuals and specifications; (2) Supporting Defendants, clients and contractors by putting clear processes in place to keep communication open and maintain project schedules and budgets and ensuring Defendants and clients receive the foundational data and management support they need to successfully complete construction work; (3) Providing construction teams around the nation the construction engineering and inspection oversight they need to keep projects compliant, on time, and on budget and ensuring SAM’s program managers are already familiar with contractor, municipal, state, and local requirements and are followed;

3 (4) Working with Defendants, contractors, consultants, trades, and vendors to keep communication open, maintain project controls, and set clear expectations for quality and performance (5) Providing adequate training for its employees, subcontractors and agents in the use of side-boom tractors or cranes; (6) Providing adequate training for its employees, subcontractors and agents in working near extremely dangerous high voltage electric powerlines; (7) Adequately supervise employees, subcontractors and agents when working with extremely dangerous equipment; (8) Warning its employees, subcontractors and agents of the dangers of working near extremely dangerous equipment; (9) Warning its employees, subcontractors and agents of the dangers of working in and around high voltage electric powerlines; (10) Instructing its employees, subcontractors and agents in the proper safety procedures when working near extremely dangerous equipment; (11) Ensuring its employees, subcontractors and agents are properly licensed to operate side-boom tractors or cranes; and (12) Preparing and providing safety policies or procedures. (13) Other acts of omission and/or commission to be specified after an adequate time for discovery or at the time of trial. 27. The death of decedent was caused solely and wholly through the gross negligence of defendants, in that Defendant, Sam Construction Services LLC, negligently hired, retained, supervised, and inspected the work of South Texas Illumination, LLC and its employees and/or servants.

Linares also asserted vicarious liability against SAM, alleging:

74. Defendant, SAM-Construction Services LLC, is vicariously liable for the damages proximately caused to Plaintiff by virtue of the negligent conduct of its employees or agents. 75. Plaintiff alleges that Defendant, SAM-Construction Services LLC, had a duty to exercise reasonable care in the training, supervising, warning, instructing, and in the preparation of safety policies and procedures, if any existed, for its employees.

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in Re SAM-Construction Services, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-sam-construction-services-llc-texapp-2022.