Lance Williams v. George Coulam

CourtCourt of Appeals of Texas
DecidedJune 24, 2010
Docket01-09-00279-CV
StatusPublished

This text of Lance Williams v. George Coulam (Lance Williams v. George Coulam) 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
Lance Williams v. George Coulam, (Tex. Ct. App. 2010).

Opinion

Opinion issued June 24, 2010.

In The

Court of Appeals

For The

First District of Texas

————————————

NO. 01-09-00279-CV

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Lance Williams, Appellant

V.

George Coulam, Appellee

On Appeal from the 506th District Court

Grimes County, Texas

Trial Court Case No. 30687

MEMORANDUM OPINION

          This appeal concerns an agreement for the sale of all the stock of the Texas Renaissance Festival, Inc. (the “Company”), which operates the Texas Renaissance Festival near Plantersville, Texas.  Appellee, George Coulam, the sole shareholder of the Company, brought suit seeking a declaratory judgment that his contract with appellant, Lance Williams, for sale of the Company was invalid.  Williams counterclaimed for breach of contract, seeking specific performance and, alternatively, damages.  Williams also filed a notice of lis pendens concerning real property owned by the Company.  The trial court rendered summary judgment in favor of Coulam and cancelled the lis pendens.  Asserting the trial court erred by granting summary judgment for Coulam, Williams’s two issues contend that he did not breach the contract by failing to provide proof of the availability of funds and that the lis pendens should not be cancelled.  We conclude that in this appeal Williams has not challenged each element of his breach of contract claim found against him by the trial court and, therefore, we must affirm the trial court’s order rendering summary judgment in favor of Coulam and denying Williams’s cross-motion.

Background

          In a “Sale and Purchase Agreement” (the “Agreement”) entered May 19, 2006, Williams agreed to purchase the Company from Coulam on a closing date 40 days later on June 28, 2006.  The Agreement required Williams to pay Coulam $10 million at closing.  The Agreement, however, did not require Williams to show, prior to the closing date, that he had the financial ability to close.  Coulam’s burden under the Agreement was to make certain business and financial records available to Williams within 10 days of the Agreement, to provide access to Company employees, and to provide a copy of any survey in Coulam’s possession. 

          One week before the closing date, Williams notified Coulam that he had not yet received a copy of a survey.  Coulam agreed to extend the closing date until a survey was prepared.  A survey was delivered to Williams in September 2006.  Williams, however, believed the survey was incomplete.  When he called in early October 2006 to inquire about the survey, Williams learned from an employee at the surveying company that the survey did not depict all of the real property owned by the Company and that portions of the real property excluded from the survey were being sold to a different buyer.  Williams then called Coulam for an explanation, and Coulam informed him that he believed the Agreement had terminated.  The transaction never closed. 

Coulam and Williams each filed lawsuits against the other and each filed motions for summary judgment against the other.  Coulam filed this suit seeking a declaration that the Agreement was not a valid contract or, in the alternative, that Coulam was excused from performance of the Agreement because Williams had not tendered the consideration due to him by the date required in the Agreement.  Coulam also filed a first motion for summary judgment asserting these grounds.  Williams counter-claimed for breach of contract, seeking specific performance of the Agreement and filed his first motion for summary judgment on these grounds.  After each of the parties responded to the opponent’s motion for summary judgment, the trial court rendered two interlocutory orders concerning the first motions for summary judgment.  The trial court denied in part Coulam’s motion for summary judgment, and it granted in part and denied in part Williams’s motion for summary judgment.  The trial court found that the Agreement was a valid contract, but because the parties extended the closing date “until we have a survey,” the closing was extended until a reasonable time following September 26, 2006, when a survey was delivered.

Although it did not decide the issue of breach in the first partial summary judgment order, the trial court ordered the parties to specifically perform the Agreement, and established a timeline for Williams to “provide written evidence of the availability of funds for closing the transaction . . . .”  Williams presented letters of interest rather than letters of commitment from two potential lenders.  The trial court determined that Williams was not entitled to specific performance because he failed to prove his ability to perform his obligation under the contract, i.e. the payment of the purchase price.

          Because the trial court had withheld a finding concerning the element of breach, the parties filed competing second motions for summary judgment concerning that element.  Coulam’s second motion for summary judgment concerning the element of breach contended that he substantially performed the material requirements of the Agreement by providing Williams the complete survey, allowing Williams to meet with Company employees, providing Williams the complete title policies, and providing Williams the other financial information specifically required by the Agreement.  Coulam asserted Williams breached the Agreement by failing to pay the amount due by the time required under the Agreement, which was the original closing date or within a reasonable amount of time after Coulam provided the survey.  Coulam also asserted that, even if he told Williams the Agreement was terminated, he timely retracted that comment by notifying Williams that he intended to perform.

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Lance Williams v. George Coulam, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lance-williams-v-george-coulam-texapp-2010.