Jack W. Lester, Jr. v. First American Bank, Bryan, Texas

CourtCourt of Appeals of Texas
DecidedNovember 30, 1993
Docket10-92-00283-CV
StatusPublished

This text of Jack W. Lester, Jr. v. First American Bank, Bryan, Texas (Jack W. Lester, Jr. v. First American Bank, Bryan, Texas) 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
Jack W. Lester, Jr. v. First American Bank, Bryan, Texas, (Tex. Ct. App. 1993).

Opinion

Lester v. First American


IN THE

TENTH COURT OF APPEALS


No. 10-92-283-CV


     JACK W. LESTER, JR.,

                                                                                              Appellant

     v.


     FIRST AMERICAN BANK, BRYAN, TEXAS,

                                                                                              Appellee


From the 85th District Court

Brazos County, Texas

Trial Court # 36,187-85


O P I N I O N


      Section 51.003 of the Texas Property Code provides that the defendant in a suit for a deficiency judgment following a non-judicial foreclosure can request the court to determine whether the property's fair market value at the date of foreclosure exceeded its sales price at the foreclosure sale. Tex. Prop. Code Ann. § 51.003(b) (Vernon Supp. 1993). If the court determines that its fair market value exceeded what it sold for, then the difference between the two amounts is offset against the deficiency. Id. § 51.003(c). Jack Lester, Jr. relied on section 51.003 when he was sued for a deficiency judgment by First American Bank. However, the court granted the bank a summary judgment on the ground that section 51.003, when applied to a deed of trust executed prior to the statute's effective date, violates the contract clause of the Texas constitution. See Tex. Const. art. I, § 16.

HAS THE QUESTION BEEN DECIDED?

      Article I, section 16, of the Texas constitution provides: "No bill of attainder, . . . or any law impairing the obligation of contracts, shall be made." Id. In November 1934 the Texas Supreme Court decided two cases dealing with this constitutional provision. See Travelers Ins. Co. v. Marshall, 124 Tex. 45, 76 S.W.2d 1007 (1934); Langever v. Miller, 124 Tex. 80, 76 S.W.2d 1025 (1934).

      In Marshall the Court held that article 2218b (Texas Moratorium Act) was unconstitutional because it impaired the obligation of contract. Article 2218b authorized courts to enjoin foreclosure sales granted under deeds of trust and to restrain execution sales under judgments. Marshall, 76 S.W.2d at 1009. Marshall is noteworthy because of the Court's discussion and interpretation of the contract clause's meaning when it was adopted in 1876 as part of the Texas constitution.

      In Langever the Supreme Court declared that article 2218 (Texas Anti-Deficiency Judgment Law) also violated the contract clause. Like section 51.003, article 2218 allowed the court to determine whether the property's "actual value" at the time of foreclosure exceeded its foreclosure sales price and, if it did, to credit the difference against the deficiency. Langever, 76 S.W.2d at 1027. Thus, the significance of Langever is in the similarity of the legal effect of article 2218 and section 51.003, whose constitutionality is now under scrutiny.

      First American Bank argues that, because of the statutes' similarity, the decision in Langever is controlling and requires a similar result here. Lester attempts to distinguish Langever on the facts, pointing out that it involved a judicial rather than a non-judicial foreclosure and that the mortgagee had already reduced the deficiency to a final judgment before article 2218 was enacted. Moreover, assuming that Langever is binding on this court, Lester questions its continuing validity as sound constitutional law in the light of three later United States Supreme Court decisions. See Gelfert v. National City Bank of New York, 313 U.S. 221, 61 S.Ct. 898, 85 L.Ed. 1299 (1941); Honeyman v. Jacobs, 306 U.S. 539, 59 S.Ct. 702, 83 L.Ed. 972 (1939); Richmond Mortg. & Loan Corp. v. Wachovia Bank & T. Co., 300 U.S. 124, 57 S.Ct. 338, 81 L.Ed. 552 (1937). He would have us "reevaluate" Langever on that basis.

      Our first step will be to determine Langever's binding effect as legal precedent under the doctrine of stare decisis. Ultimately, we hold that Langever is not controlling authority in this case. Finally, we will examine the opinion in Marshall, as well as the three United States Supreme Court cases mentioned above, for an understanding of the meaning of the contract clause of the Texas constitution. Based upon our interpretation of the contract clause and the relevant caselaw, both federal and state, we will hold that section 51.003 passes constitutional muster. Accordingly, we will reverse the summary judgment and remand the cause for trial.

PREAMBLE

      As a preamble to our examination of Langever's binding effect, we briefly sketch the doctrine of stare decisis:

As originally conceived and as generally applied, the doctrine of stare decisis governs only the determination of questions of law and its observance does not depend upon identity of parties. After a principle, rule or proposition of law has been squarely decided by the Supreme Court, . . . the decision is accepted as a binding precedent by the same court or other courts of lower rank when the very point is again presented in a subsequent suit between different parties.

See Swilley v. McCain, 374 S.W.2d 871, 875 (Tex. 1964). The binding effect of a prior decision cannot be determined without reference to its important facts. See Meyer v. Texas Nat. Bank of Commerce of Houston, 424 S.W.2d 417, 419 (Tex. 1968). In fact, the doctrine of stare decisis only applies if the facts on which the prior case is founded are substantially the same as those in the subsequent suit. McKenzie Const. Co. v. City of San Antonio, 50 S.W.2d 349, 353 (Tex. Civ. App.—San Antonio 1932, writ ref'd).

      Dictum, which includes expressions of opinion on a point or issue not necessarily involved in the case, will not create binding precedent under stare decisis. See Boswell v. Pannell, 107 Tex. 433, 180 S.W. 593, 597 (1915); Grigsby v. Reib, 105 Tex. 597, 153 S.W.

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Related

Green v. Biddle
21 U.S. 1 (Supreme Court, 1823)
Home Building & Loan Assn. v. Blaisdell
290 U.S. 398 (Supreme Court, 1934)
Honeyman v. Jacobs
306 U.S. 539 (Supreme Court, 1939)
Gelfert v. National City Bank of NY
313 U.S. 221 (Supreme Court, 1941)
Davenport v. Garcia
834 S.W.2d 4 (Texas Supreme Court, 1992)
Palestine Contractors, Inc. v. Perkins
386 S.W.2d 764 (Texas Supreme Court, 1964)
Swilley v. McCain
374 S.W.2d 871 (Texas Supreme Court, 1964)
Meyer v. Texas National Bank of Commerce of Houston
424 S.W.2d 417 (Texas Supreme Court, 1968)
Mitchell v. Town of Refugio
265 S.W.2d 261 (Court of Appeals of Texas, 1954)
Boswell v. Pannell
180 S.W. 593 (Texas Supreme Court, 1915)
McKenzie Const. Co. v. City of San Antonio
50 S.W.2d 349 (Court of Appeals of Texas, 1932)
Grigsby v. Reib
153 S.W. 1124 (Texas Supreme Court, 1913)
Travelers Insurance v. Marshall
76 S.W.2d 1007 (Texas Supreme Court, 1934)
Langever v. Miller
76 S.W.2d 1025 (Texas Supreme Court, 1934)
Parker v. Bailey
15 S.W.2d 1033 (Texas Commission of Appeals, 1929)
Stark v. American Nat. Bank of Beaumont
100 S.W.2d 208 (Court of Appeals of Texas, 1936)
Eubanks v. State
203 S.W.2d 339 (Court of Appeals of Texas, 1947)

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Jack W. Lester, Jr. v. First American Bank, Bryan, Texas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jack-w-lester-jr-v-first-american-bank-bryan-texas-texapp-1993.