Laughlin Environmental, Inc. v. United Pacific Insurance Company and JPF Holding, Inc. and Premier Towers, L.P.

CourtCourt of Appeals of Texas
DecidedJanuary 29, 2004
Docket14-02-00639-CV
StatusPublished

This text of Laughlin Environmental, Inc. v. United Pacific Insurance Company and JPF Holding, Inc. and Premier Towers, L.P. (Laughlin Environmental, Inc. v. United Pacific Insurance Company and JPF Holding, Inc. and Premier Towers, L.P.) 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
Laughlin Environmental, Inc. v. United Pacific Insurance Company and JPF Holding, Inc. and Premier Towers, L.P., (Tex. Ct. App. 2004).

Opinion

Reversed and Remanded and Opinion filed January 29, 2004

Reversed and Remanded and Opinion filed January 29, 2004.

In The

Fourteenth Court of Appeals

____________

NO. 14-02-00639-CV

LAUGHLIN ENVIRONMENTAL, INC., Appellant

V.

PREMIER TOWERS, L.P. AND JPF HOLDINGS, INC., Appellees

________________________________________________________________

On Appeal from the 189th District Court

Harris County, Texas

Trial Court Cause No. 01-19113A

________________________________________________________________

O P I N I O N

            In this case, we must determine if a “Payment and Performance Bond” qualifies as a statutory payment bond under sections 53.202 and 53.211 of the Texas Property Code.  Appellant Laughlin Environmental, Inc., the lien claimant, challenges the trial court’s summary judgment in favor of the property owner, appellee Premier Towers, L.P., arguing the bond at issue does not satisfy the statutory requirements and thus does not provide the owner the corresponding statutory protections.  We agree, reverse the trial court’s judgment, and remand this case for further proceedings.

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I.  Factual and Procedural Background

            JPF Holdings, Inc., the original property owner, entered into a written contract with Vanco Insulation Abatement, Inc., under which Vanco was to provide various asbestos abatement services relating to the property located at

914 Main Street
in Houston, Texas (“Property”).  The original contract amount was $1,295,000.  In connection with the construction work on the Property, Vanco, as principal, and United Pacific Insurance Company, as surety, executed a “Performance and Payment Bond” (hereinafter “Bond”) in favor of JPF Holdings, as obligee. 

            Laughlin alleges it entered into a subcontract with Vanco for work on this project and that when Vanco failed to pay Laughlin for that work, Laughlin timely filed a lien affidavit asserting a mechanic’s and materialmen’s lien (“Lien”) against the Property.  JPF Holdings later conveyed the Property to Premier Towers, L.P. by a special warranty deed.  Laughlin sued the surety (United Pacific Insurance Company), the original obligee (JPF Holdings), and the current owner of the Property (Premier), seeking to recover on the Bond and also seeking to foreclose the Lien.[1]

            Premier and JPF Holdings each filed separate motions for summary judgment.  Premier’s motion asserted that the Bond satisfied the requirements of sections 53.202 and 53.211 of the Texas Property Code and therefore protected the Property from foreclosure of the Lien under section 53.201(b) of the Texas Property Code.  The trial court granted Premier’s motion as well as the separate motion filed by JPF Holdings.  The trial court also cancelled and removed all clouds on the title to the Property relating to the Lien claim.  The trial court severed Laughlin’s claims against JPF Holdings and Premier and these defendants’ counterclaims against Laughlin from the claims involving the surety to make the court’s judgment final.  Laughlin now appeals the trial court’s summary judgment in favor of Premier, but does not appeal the summary judgment in favor of JPF Holdings. 

II.  Issues and Analysis

            In a single issue, Laughlin asserts the trial court erred in granting summary judgment and in determining that the Bond satisfies the statutory requirements under sections 53.202 and 53.211 of the Texas Property Code for the following reasons:

            (1)       The Bond is not in a penal amount at least equal to the original contract amount.

(2)       The Bond conditions payments to payment-bond claimants “subject to the Obligee’s priority.”

            (3)       The Bond is not conditioned on the prompt payment of claims.

            (4)       The Bond limits payment-bond payments to the amount paid by the obligee to the principal.

            For reasons explained below, we need not address all of these arguments as it is clear from the record that the Bond was not filed in compliance or attempted compliance with the statute, and thus provides no protection from lien claims on the Property.

The Texas Payment Bond Statute

            Texas is one of relatively few states with a statutory form of payment bond for private construction projects.[2]  This form of bond provides an alternative means of dealing with potential lien claims on real property.[3]  Under our state’s statutory regime, an owner can require his general contractor to obtain a payment bond for the protection of those furnishing labor or materials to the project.  See Tex. Prop. Code

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Related

Staff Industries, Inc. v. Hallmark Contracting, Inc.
846 S.W.2d 542 (Court of Appeals of Texas, 1993)
Sentry Insurance Co. v. Radcliff Materials of Texas, Inc.
687 S.W.2d 437 (Court of Appeals of Texas, 1985)
Sherwin-Williams Co. v. American Indemnity Co.
504 S.W.2d 400 (Texas Supreme Court, 1973)

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Bluebook (online)
Laughlin Environmental, Inc. v. United Pacific Insurance Company and JPF Holding, Inc. and Premier Towers, L.P., Counsel Stack Legal Research, https://law.counselstack.com/opinion/laughlin-environmental-inc-v-united-pacific-insura-texapp-2004.