Laura Elizabeth Ostteen v. James Allen Holmes, Sr.

CourtCourt of Appeals of Texas
DecidedAugust 22, 2024
Docket05-23-01150-CV
StatusPublished

This text of Laura Elizabeth Ostteen v. James Allen Holmes, Sr. (Laura Elizabeth Ostteen v. James Allen Holmes, Sr.) 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
Laura Elizabeth Ostteen v. James Allen Holmes, Sr., (Tex. Ct. App. 2024).

Opinion

Affirmed in Part, Reversed and Remanded in Part, and Opinion Filed August 22, 2024

S In The Court of Appeals Fifth District of Texas at Dallas No. 05-23-01150-CV

LAURA ELIZABETH OSTTEEN, Appellant V. JAMES ALLEN HOLMES, SR., Appellee

On Appeal from the 95th District Court Dallas County, Texas Trial Court Cause No. DC-23-14702

MEMORANDUM OPINION Before Justices Partida-Kipness, Pedersen, III, and Carlyle Opinion by Justice Partida-Kipness Appellant Laura Ostteen appeals from the trial court’s denial of her motion to

dismiss Appellee James Holmes, Sr.’s claims under the Texas Citizens Participation

Act (TCPA). See TEX. CIV. PRAC. & REM. CODE §§ 27.001–.011. In four issues,

Ostteen asserts: (1) the trial court abused its discretion in sustaining Holmes’s

objections to her declarations and striking Ostteen’s reply and supplemental

declaration; (2) the trial court erred in denying the motion to dismiss; (3) the trial

court erred in concluding Ostteen’s motion to dismiss was frivolous and filed solely

for purposes of delay; and (4) the trial court erred in awarding Holmes attorney’s fees and costs. We reverse the attorney’s fees award due to insufficient evidence and

remand for a redetermination of those fees. We otherwise affirm the trial court’s

judgment.

BACKGROUND

I. Factual Background

Holmes purchased a vacant lot at 4932 Reiger Avenue in Dallas on August 2,

2023. The lot sits in a heavily-trafficked area of East Dallas and is open on three

sides to Reiger Avenue, Barry Avenue, and Elm Alley. Because of significant

pedestrian and car traffic in the area, the lot has a history of accumulating trash,

debris, and human waste, particularly when not fenced. Prior to Holmes’s purchase,

the City of Dallas had periodically imposed code violations against the property

related to trash, debris, and excessive vegetation. Shortly after his purchase of the

property, Holmes conferred with the city on ways to improve the lot, remove

concerns, and avoid citations. Holmes learned from the city that the overgrown

vegetation (trees and brush) created shade and shelter used by vagrants to rest and

sometimes engage in drug use. Following the city’s advice, Holmes began sending

work crews to cut the vegetation and to remove debris and trash in August 2023.

Holmes scheduled tree and shrub removal to take place on September 6, 2023. On

August 26-27th, Holmes also had workers install a fence on the same footprint of a

prior fence.

–2– During the August lawn care and fence installation, the workers reported

people would sometimes make derogatory comments or gestures toward the

workers. One of these people was later identified as Ostteen. Sometime in late

August or early September—a few days before scheduled tree removal work was to

take place—Ostteen approached Holmes’s agent who was on the property surveying

the upcoming tree work. According to Holmes, Ostteen confronted the agent in a

hostile manner.

The tree-removal service began work the morning of September 6, 2023. The

workers cut down three small hackberry trees and were tasked with trimming up

several large trees at the back of the lot. Sometime after the work commenced,

Ostteen confronted the tree-removal service and Holmes’s agent. According to

Holmes, Ostteen trespassed on the property while confronting them, stomping

around the lot, touching the trees and fence, all while screaming and cursing. Ostteen

claimed she confronted Holmes’s workers after she caught them “illegally removing

protected trees from the city’s right of way,” and asked to see a permit. “Fearing for

[her] safety,” Ostteen called the police and also contacted City of Dallas arborists

regarding the alleged illegal tree removal. Police arrived, as did city arborists, who

apparently took some measurements of the trees. The confrontation de-escalated and

no action was taken by the police or arborists. Ostteen later posted photographs of

the incident on social media.

–3– After the September 6th events, Holmes learned of Ostteen’s identity and her

nearby residence at 4926 Reiger Avenue. Holmes learned that during August 2023,

Ostteen had frequently trespassed on the lot at 4932 Reiger Avenue. Ostteen posted

online pictures of herself walking and dancing on the property, sometimes in the

nude, and sometimes holding a human skull replica. Holmes also discovered online

posts in which Ostteen complains of the ongoing changes to the property. According

to Holmes, Ostteen maligns him as greedy and violent and refers to him as an

“avaricious, rapist developer[.]”

II. Procedural History

Holmes subsequently filed suit against Ostteen. His original petition described

Ostteen’s behavior related to 4932 Reiger Avenue, including the events of

September 6th. Holmes brought claims for trespass, public and private nuisance,

and business disparagement. Holmes asserted Ostteen’s trespassory and tortious

behavior had discouraged his contractors from working on the lot and made it

difficult for him to find replacement workers. Holmes asserted he and his employee

had to continue the clean-up and lawn work themselves at additional cost. Holmes

sought actual damages and injunctive relief.

Ostteen answered, generally denying Holmes’s allegations, and moved to

dismiss under the TCPA. Ostteen suggested Holmes’s suit was in response to her

exercise of the right of free speech, right of association, and right to petition on a

matter of public concern—the illegal removal of public trees. Ostteen’s motion to

–4– dismiss was not accompanied by any legal authority or substantive analysis

regarding application of the TCPA.

Holmes amended his petition twice, removing his public nuisance claims and

some of the references to the events of September 6th. Holmes also contended he

was not seeking to hold Ostteen liable specifically for the events of September 6th,

but for her trespassing, fostering a private nuisance, and business disparagement

activities.

Ostteen later filed a declaration in support of her motion to dismiss. Therein,

Ostteen describes the events leading up to September 6th. She claimed that, worried

about development of the lot and tree removal, she contacted City of Dallas arborists.

Ostteen claimed she was told the trees were protected and their removal would

require a permit. Ostteen admitted walking across the property but asserted she did

no damage. Holmes filed objections to Ostteen’s declaration.

The hearing on Ostteen’s motion to dismiss was set for November 1, 2023.

Holmes filed his response to the motion to dismiss seven days prior to the hearing.

Holmes attached an affidavit in support of his response and suit. Just after 11:00 p.m.

on October 31st, approximately fourteen hours before the hearing, Ostteen filed a

reply to Holmes’s response, largely containing objections to Holmes’s affidavit but

providing little substantive analysis of the TCPA or Holmes’s response. Ostteen

attached a supplemental declaration to this reply in which she challenged Holmes’s

personal knowledge to support his affidavit.

–5– At the November 1st hearing, Holmes objected to Ostteen’s reply as untimely,

in part because it violated Dallas County Local Rule 2.09, which requires reply briefs

be filed at least three days before the hearing. After the hearing, the trial court signed

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