Loretta Cuba v. Olivia Evonne Williams

CourtCourt of Appeals of Texas
DecidedApril 18, 2019
Docket01-18-00122-CV
StatusPublished

This text of Loretta Cuba v. Olivia Evonne Williams (Loretta Cuba v. Olivia Evonne Williams) 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
Loretta Cuba v. Olivia Evonne Williams, (Tex. Ct. App. 2019).

Opinion

Opinion issued April 18, 2019

In The

Court of Appeals For The

First District of Texas ———————————— NO. 01-18-00122-CV ——————————— LORETTA CUBA, Appellant V. OLIVIA EVONNE WILLIAMS, Appellee

On Appeal from the 215th District Court Harris County, Texas Trial Court Case No. 2017-36144

MEMORANDUM OPINION

Appellant, Loretta Cuba, challenges the trial court’s order dismissing her

negligence suit against appellee, Olivia Evonne Williams. In five issues, Cuba

contends that the trial court erred in dismissing her suit.

We affirm. Background

On May 30, 2017, Cuba filed her original petition, alleging that on June 6,

2015, Williams “rear ended” Cuba’s car with her sport utility vehicle (“SUV”).

According to Cuba, she sustained bodily injuries as a result of Williams’s failure to

“keep . . . lookout as a person of ordinary prudence would have kept under the same

or similar circumstances” and Williams’s operation of her SUV in a careless and

reckless manner and “with [a] disregard for the public.” Cuba brought a negligence

claim against Williams and sought damages for past and future medical expenses,

past and future physical pain and suffering, past and future mental anguish, and past

and future physical impairment.

Williams generally denied Cuba’s allegations and asserted the affirmative

defense of statute of limitations, arguing that because Cuba did not exercise due

diligence in serving her until after the statute of limitations had expired, the date of

service did not relate back to the date of the filing of Cuba’s original petition and

Cuba’s negligence claim was barred.

Subsequently, Williams filed a motion titled, “Motion to Show Cause as to

Why [Cuba]’s Case Should not be Dismissed for Failing to Exercise Due Diligence

in Serving [Williams].” In her motion, Williams asserted that under Texas law, “a

person must bring suit for personal injury no[] later than two years after the day the

2 cause of action accrues,”1 and to “bring suit” within the two-year statute of

limitations, a plaintiff must not only file her suit within the limitations period, but

also use diligence to have the defendant served with process. (Internal quotations

omitted.) When a plaintiff files her original petition within the limitations period,

but does not serve a defendant until after the limitations period has expired, the date

of service relates back to the date of the filing of the petition if the plaintiff exercised

diligence in effecting service. When a plaintiff does not exercise due diligence in

serving the defendant until after the limitations period has expired, a timely filed suit

will not interrupt the running of limitations. The duty to exercise diligence is a

continuous one, extending from the date the original petition is filed until the date

that service is obtained. An unexplained delay in effecting service constitutes a lack

of diligence as a matter of law.

According to Williams, on May 30, 2017, Cuba filed her original petition,

alleging that on June 6, 2015, a car accident occurred between Cuba and Williams

and Cuba suffered injuries. Thus, pursuant to the two-year statute of limitations,

Cuba was required to bring suit against Williams on or before June 6, 2017.

Although Cuba filed her original petition within the limitations period, Williams was

not served until September 14, 2017—after the limitations period had expired.

Because Williams pled the affirmative defense of statute of limitations and the

1 See TEX. CIV. PRAC. & REM. CODE § 16.003(a).

3 record showed that she was not served until September 14, 2017, after the limitations

period had expired, Williams asserted that Cuba was required to prove due diligence

in both the issuance of citation and the service of citation, which she could not do as

a matter of law. Williams requested that the trial court dismiss with prejudice Cuba’s

negligence claim against her based on the affirmative defense of statute of

limitations. In her motion, Williams also requested that the trial court take judicial

notice of its own record.

In her response to Williams’s motion, Cuba asserted that she timely filed her

original petition seeking damages caused by Williams’s negligence. On June 9,

2017, ten days after Cuba filed her original petition and only three days after the

limitations period expired, Cuba’s attorney “requested service of process

on . . . Williams” and paid $77.00 “to Harris County Constable Alan Rosen, Precinct

One to serve citation upon [Williams].” Thus, according to Cuba, she “was not

negligent in placing a citation in the hands of a county constable for service of

process on” Williams, and Cuba could not be responsible for the acts of the Harris

County Constable or “for the timing of the Constable’s office in serving” Williams.

Cuba attached to her response the affidavit of her attorney and a receipt.

After a hearing of which no record was taken, the trial court granted

Williams’s motion based on the affirmative defense of statute of limitations and

4 dismissed Cuba’s negligence claim against Williams with prejudice. Cuba filed a

motion for new trial, which the trial court denied.

Nature of Motion

In her first issue, Cuba argues that the trial court erred in dismissing her

negligence claim against Williams because Williams filed a motion to show cause,

rather than a motion for summary judgment, and “a show cause hearing [could] not

be used to adduce evidence on the merits of [Williams]’s claim” that Cuba failed to

use due diligence in serving Williams.

It is well settled that the nature of a motion is determined by its substance,

rather than its title or caption. See In re Brookshire Grocery Co., 250 S.W.3d 66, 72

(Tex. 2008) (orig. proceeding); State Bar of Tex. v. Heard, 603 S.W.2d 829, 833

(Tex. 1980); see also TEX. R. CIV. P. 71; Surgitek, Bristol–Myers Corp. v. Abel, 997

S.W.2d 598, 601 (Tex. 1999) (“We should not be so constrained by the form or

caption of a [motion].”). The substance of a motion is gleaned from the body of the

motion and the prayer for relief. Finley v. J.C. Pace Ltd., 4 S.W.3d 319, 320 (Tex.

App.—Houston [1st Dist.] 1999, no pet.). We examine the substance of Williams’s

motion and the relief sought to determine how to treat the motion. See Poppe v.

Poppe, No. 01-08-00021-CV, 2009 WL 566490, at *2 (Tex. App.—Houston [1st

Dist.] Mar. 5, 2009, no pet.) (mem. op.).

5 To prevail on a summary-judgment motion, a movant has the burden of

proving that she is entitled to judgment as a matter of law and there is no genuine

issue of material fact. TEX. R. CIV. P. 166a(c); Cathey v. Booth, 900 S.W.2d 339,

341 (Tex. 1995). A defendant moving for summary judgment as a matter of law

must either: (1) disprove at least one element of the plaintiff’s cause of action, or

(2) plead and conclusively establish each essential element of her affirmative

defense. Cathey, 900 S.W.2d at 341; Yazdchi v. Bank One, Tex., N.A., 177 S.W.3d

399, 404 (Tex. App.—Houston [1st Dist.] 2005, pet. denied). Once the movant

meets her burden, the burden shifts to the non-movant to raise a genuine issue of

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