John R. Haas and Frances Rawlings Haas v. Ashford Hollow Community Improvement Assoc., Inc.

CourtCourt of Appeals of Texas
DecidedDecember 14, 2006
Docket14-05-00071-CV
StatusPublished

This text of John R. Haas and Frances Rawlings Haas v. Ashford Hollow Community Improvement Assoc., Inc. (John R. Haas and Frances Rawlings Haas v. Ashford Hollow Community Improvement Assoc., Inc.) 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
John R. Haas and Frances Rawlings Haas v. Ashford Hollow Community Improvement Assoc., Inc., (Tex. Ct. App. 2006).

Opinion

Affirmed and Opinion filed December 14, 2006

Affirmed and Opinion filed December 14, 2006.

In The

Fourteenth Court of Appeals

_______________

NO. 14-05-00071-CV

JOHN R. HAAS, Appellant

V.

ASHFORD HOLLOW COMMUNITY IMPROVEMENT ASSOCIATION, INC., Appellee

On Appeal from the County Civil Court at Law No. 3

Harris County, Texas

Trial Court Cause No. 804,328

O P I N I O N


Appellant, John R. Haas, appeals from a judgment awarding appellee, Ashford Hollow Community Improvement Association, Inc. (Athe Association@), delinquent maintenance assessments for 2003 and 2004 and ordering foreclosure on a lien securing payment of the assessments.  In five issues, Haas contends (1) the trial court lacked jurisdiction to enforce a lien on his real property, (2) the trial court lacked jurisdiction over the Association=s claim to recover the assessments, (3) the trial court erred by awarding 2004 assessments, (4) the trial court erred by awarding attorney=s fees, and (5) the attorney=s fees were excessive.  We affirm.

I.  Background

In October 2003, the Association sued Haas, a property owner, alleging he breached the restrictive covenants governing his subdivision by failing to pay maintenance assessments for 2003.  The Association also alleged that it anticipated Haas would refuse to pay the 2004 assessments, which would become due between the filing of the petition and the trial.  Thus, the Association sought recovery of assessments for 2003 and 2004.  The Association further alleged that the restrictive covenants allowed it to place a lien on Haas=s property to secure payment of the assessments, and the Association sought to foreclose its lien in this suit.

The trial court conducted a bench trial in August 2004.  At the start of the trial, the trial court held a hearing to consider Haas=s plea to the jurisdiction that was included in his live answer and his Amotion for partial directed verdict@ on the ground that the Association was not entitled to recover attorney=s fees.  The trial court denied the plea to the jurisdiction and the Amotion for partial directed verdict.@  The parties then stipulated regarding the amounts of the assessments for 2003 and 2004 and that they were delinquent.  The only remaining issue to be tried concerned the amount of the Association=s attorney=s fees. Following presentation of evidence, the trial court entered judgment for the Association to recover $716.11, plus post-judgment interest and attorneys= fees.  In addition, the trial court ordered that the Association have a lien on the property as set forth in the restrictive covenants and ordered foreclosure on the lien.

II.  Jurisdiction to Enforce the Lien on Real Property


In his first issue, Haas contends the trial court did not have jurisdiction to enforce the lien on his real property because the amount in controversy was less than the minimum jurisdictional limits of a statutory county court at law.  Whether a court has subject matter jurisdiction is a question of law that we review de novoTexas Dep=t of Parks & Wildlife v. Miranda, 133 S.W.3d 217, 226 (Tex. 2004).  As we will discuss, we disagree that the amount in controversy with respect to Haas=s claim to recover the assessments was less than the minimum jurisdictional limit of the court.  Regardless, the trial court had jurisdiction to enforce the lien on Haas=s property, irrespective of the amount in controversy.

Section 25.0003 of the Texas Government Code governs the jurisdiction in general of statutory county courts and prescribes the monetary jurisdictional limits of statutory county courts.  See Tex. Gov=t Code Ann. ' 25.0003 (Vernon Supp. 2006).  Section 25.1032 of the Government Code contains additional jurisdictional provisions particular to Harris County civil courts at law.  Tex. Gov=t Code Ann. ' 25.1032 (Vernon 2004).  Section 25.1032(c)(3) provides, AIn addition to other jurisdiction provided by law, a [Harris] county civil court at law has jurisdiction to . . . hear a suit for enforcement of a lien on real property . . .@  Id. ' 25.1032(c)(3) (emphasis added).

Therefore, contrary to Haas=s contention, section 25.1032(c)(3) does not make a Harris County Civil Court at Law=s jurisdiction to hear a suit to enforce a lien on real property dependent upon the amount of the indebtedness secured by the lien or upon the trial court=s jurisdiction to award the indebtedness as monetary damages.  See id.  Rather, the trial court=s jurisdiction to hear a suit to enforce a lien on real property is based on subject matter, not the amount in controversy.  See id.; see also In re Burlington N. and Santa Fe Ry. Co., 12 S.W.3d 891, 899 (Tex. App.CHouston [14th Dist.] 2000, orig. proceeding [mand. denied]) (holding Fort Bend County Court at Law had jurisdiction to issue injunction in eminent domain suit although county did not state an amount in controversy within court=s jurisdictional limits because Legislature had expressly conferred jurisdiction on court to hear eminent domain cases based on subject matter, not the amount in controversy).


Moreover, the Association alleged that the restrictive covenants entitled it to place and foreclose a lien for outstanding assessments.[1]

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John R. Haas and Frances Rawlings Haas v. Ashford Hollow Community Improvement Assoc., Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/john-r-haas-and-frances-rawlings-haas-v-ashford-hollow-community-texapp-2006.