Jeanine v. Richardson v. Estate of H.A. Smith and Randy A. Dishongh

CourtCourt of Appeals of Texas
DecidedNovember 13, 2014
Docket01-14-00034-CV
StatusPublished

This text of Jeanine v. Richardson v. Estate of H.A. Smith and Randy A. Dishongh (Jeanine v. Richardson v. Estate of H.A. Smith and Randy A. Dishongh) 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
Jeanine v. Richardson v. Estate of H.A. Smith and Randy A. Dishongh, (Tex. Ct. App. 2014).

Opinion

Opinion issued November 13, 2014.

In The

Court of Appeals For The

First District of Texas ———————————— NO. 01-14-00034-CV ——————————— JEANINE V. RICHARDSON, Appellant V. ESTATE OF H.A. SMITH AND RANDY A. DISHONGH, Appellees

On Appeal from the County Civil Court at Law No. 3 Harris County, Texas Trial Court Case No. 1032728

MEMORANDUM OPINION

This appeal arises from a dispute between a tenant, Jeanine Richardson, and

her landlords, the Estate of H.A. Smith and the estate’s executor Randy Dishongh

(collectively, “Dishongh”). In seven issues, Richardson challenges the legal and

factual sufficiency of the evidence supporting the trial court’s finding that Dishongh is not liable for withholding part of Richardson’s security deposit.

Particularly relevant to our opinion here, she contends that the trial court erred in

finding that Dishongh did not act in bad faith. We affirm.

Background

Richardson rented a house from Dishongh. She gave Dishongh a refundable

$3,600 security deposit, which included a $250 pet fee. After living in the house

for over a year, Richardson properly terminated the month-to-month lease and

surrendered the property.

According to Dishongh, Richardson left the house in very poor condition.

Dishongh deducted the $250 pet fee plus an additional $730 from Richardson’s

refundable security deposit to cover the costs of restoring and cleaning the house.

He returned the remaining $2,620 to Richardson 31 days after she moved out. He

also gave her an itemized list of deductions, but testified that he forgot to include

the pet-fee deduction in the list.

Richardson filed this lawsuit in small-claims court asserting two causes of

action under section 92.109 of the Texas Property Code. TEX. PROP. CODE ANN.

§ 92.109 (West 2014). First, Richardson alleged that Dishongh withheld an

itemized list of security-deposit deductions in bad faith. TEX. PROP. CODE ANN. §

92.109(b). Both parties as well as the trial court refer to this requirement as a

“proper accounting” and for convenience so shall we. Second, Richardson alleged

2 that Dishongh retained a portion of Richardson’s security deposit in bad faith. TEX.

PROP. CODE ANN. § 92.109(a).

After the small-claims court ruled against her, Richardson appealed to the

county court at law. That court held a bench trial and entered a final judgment

against Richardson. Richardson timely appealed to this Court.

Bad Faith

In her first, second, and third issues, Richardson challenges the legal and

factual sufficiency of the trial court’s finding that Dishongh did not act in bad faith.

A landlord who does not act in bad faith will not be liable under section 92.109.

TEX. PROP. CODE ANN. § 92.109(a)–(b). “Bad faith implies an intention to deprive

the tenant of a lawfully due refund.” Hardy v. 11702 Mem’l, Ltd., 176 S.W.3d 266,

271 (Tex. App.—Houston [1st Dist.] 2004, no pet.) “A landlord who fails either to

return a security deposit or to provide a written description and itemization of

deductions on or before the 30th day after the date the tenant surrenders possession

is presumed to have acted in bad faith.” TEX. PROP. CODE ANN. § 92.109(d). Once

the presumption of bad faith arises, the burden shifts to the landlord to rebut the

presumption and “prove his good faith, i.e., ‘honesty in fact in the conduct or

transaction concerned.’” Hardy, 176 S.W.3d at 271 (quoting Wilson v. O’Connor,

555 S.W.2d 776, 780 (Tex. App.—Dallas 1977, writ dism’d)).

3 A. Standards of review

Although the standards of review for factual and legal sufficiency of the

evidence are well established, the standards in this case must account for the

burden-shifting framework of section 92.109.

1. Standard of review when Richardson has the burden of proof

To successfully challenge the legal sufficiency of a factfinder’s ruling that

the complaining party failed to meet its burden of proof, “she must demonstrate on

appeal that the evidence establishes, as a matter of law, all vital facts” necessary to

meet the burden of proof. Dow Chem. Co. v. Francis, 46 S.W.3d 237, 241 (Tex.

2001). We begin our review by examining only the evidence that supports the

challenged finding, ignoring all evidence to the contrary. Id. “[I]f there is no

evidence to support the fact finder’s [finding], then, the entire record must be

examined to see if the contrary proposition is established as a matter of law.”

Sterner v. Marathon Oil Co., 767 S.W.2d 686, 690 (Tex. 1989). We will affirm the

factfinder’s finding unless the evidence conclusively establishes the opposite

conclusion as a matter of law. Id. at 241 (citing Croucher v. Croucher, 660 S.W.2d

55, 58 (Tex. 1983)).

To successfully challenge the factual sufficiency of a factfinder’s finding

that the complaining party failed to meet its burden of proof, “she must

demonstrate on appeal that the adverse finding is against the great weight and

4 preponderance of the evidence.” Dow Chem. Co., 46 S.W.3d at 242. We consider

and weigh all the evidence, and uphold the challenged finding unless “the evidence

is so weak” or “the finding is so against the great weight and preponderance of the

evidence that it is clearly wrong and unjust.” Id. A court of appeals may not

reverse the judgment unless the court clearly states why the factfinder’s finding is

factually insufficient. Pool v. Ford Motor Co., 715 S.W.2d 629, 635 (Tex. 1986).

2. Standard of review when Dishongh has the burden of proof

To successfully challenge the legal sufficiency of a factfinder’s finding that

an opposing party met its burden of proof, the complaining party must show that

there is no evidence that “would enable reasonable and fair-minded people to reach

the verdict under review.” City of Keller v. Wilson, 168 S.W.3d 802, 827 (Tex.

2005). When reviewing a legal-sufficiency challenge, we consider all of the

evidence supporting the judgment, “credit[ing] favorable evidence if reasonable

jurors could, and disregard[ing] contrary evidence unless reasonable jurors could

not.” City of Keller, 168 S.W.3d at 827. We consider the evidence in the light most

favorable to the findings and indulge every reasonable inference that would

support them. Id. at 822; see Zenner v. Lone Star Striping & Paving L.L.C., 371

S.W.3d 311, 314–15 (Tex. App.—Houston [1st Dist.] 2012, pet. denied).

To successfully challenge the factual sufficiency of a factfinder’s finding

that an opposing party met its burden of proof, the complaining party must show

5 that the adverse finding is “so against the great weight and preponderance of the

evidence as to be clearly wrong and unjust.” Ortiz v. Jones, 917 S.W.2d 770, 772

(Tex. 1996); accord Cain v. Bain, 709 S.W.2d 175, 176 (Tex. 1986). In a factual-

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Related

Hardy v. 11702 Memorial, Ltd.
176 S.W.3d 266 (Court of Appeals of Texas, 2004)
Pool v. Ford Motor Co.
715 S.W.2d 629 (Texas Supreme Court, 1986)
Dow Chemical Co. v. Francis
46 S.W.3d 237 (Texas Supreme Court, 2001)
Croucher v. Croucher
660 S.W.2d 55 (Texas Supreme Court, 1983)
Ortiz v. Jones
917 S.W.2d 770 (Texas Supreme Court, 1996)
City of Keller v. Wilson
168 S.W.3d 802 (Texas Supreme Court, 2005)
Wilson v. O'CONNOR
555 S.W.2d 776 (Court of Appeals of Texas, 1977)
Sterner v. Marathon Oil Co.
767 S.W.2d 686 (Texas Supreme Court, 1989)
Cain v. Bain
709 S.W.2d 175 (Texas Supreme Court, 1986)

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Jeanine v. Richardson v. Estate of H.A. Smith and Randy A. Dishongh, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jeanine-v-richardson-v-estate-of-ha-smith-and-rand-texapp-2014.