Manuel Villegas v. Heidi Henke Morse

CourtCourt of Appeals of Texas
DecidedJune 18, 2008
Docket10-06-00415-CV
StatusPublished

This text of Manuel Villegas v. Heidi Henke Morse (Manuel Villegas v. Heidi Henke Morse) 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
Manuel Villegas v. Heidi Henke Morse, (Tex. Ct. App. 2008).

Opinion

IN THE

TENTH COURT OF APPEALS

 

No. 10-06-00415-CV

Manuel Villegas,

                                                                                    Appellant

 v.

Heidi Henke Morse,

                                                                                    Appellee


From the County Court

Walker County, Texas

Trial Court No. 8080CV

MEMORANDUM  Opinion


Manuel Villegas challenges a default judgment entered in favor of Heidi Morse.  Villegas asserts that the trial court erred in denying his second and revised second motion for new trial because of a mistake in determining whether he had been served.  In three issues, Villegas argues that the trial court abused its discretion in entering the default judgment and awarding damages supported by insufficient evidence.  We will reverse and remand for a new trial. 

Background

Morse was involved in a vehicle accident with Villegas, an insured of Affirmative Insurance.  After negotiations to resolve the dispute failed, Morse filed a personal injury suit against Villegas on November 18, 2005.  That same day, Morse’s attorney forwarded a copy of the petition to Affirmative Insurance, and shortly thereafter Affirmative Insurance forwarded the file to its outside defense counsel, Mark Burck of Burck, Lapidus & Lanza, P.C., to handle the case.  Burck alleges that after receiving information about the case, he contacted the clerk’s office to determine the status of service on Villegas and was told that Villegas had not been served.  Janya Bishop, Burck’s assistant, stated in her affidavit that she then began to check the status of service with the clerk’s office every two weeks.  Burck also sent a letter to Morse’s counsel asking that he inform him when Villegas had been served.  In a letter response, Morse’s attorney refused to do so.

            Villegas was served on December 28, 2005.  Morse filed the return of service on January 9, 2006, and Villegas failed to timely file an answer.  On January 31, 2006, Morse appeared at a default judgment hearing, offered evidence, and the trial court signed a no-answer default judgment in her favor for $167,733.86.  Burck claims that, unaware of the default judgment, his firm continued to do routine service checks with the clerk’s office, as well as negotiate Morse’s settlement claim, but was repeatedly told that Villegas had not been served.  Burck claims that on March 3, 2006, he discovered that service was achieved on Villegas; he immediately filed an answer and later filed a motion for new trial.  The trial court declined to consider Villegas’s first motion for new trial, believing that it had lost plenary power.  Villegas filed a petition for writ of mandamus and a restricted appeal in this court, arguing that the default judgment was not a final judgment.  We agreed and abated the appeal until the trial court signed the final judgment.  The trial court subsequently held a hearing and entered a final no-answer default judgment.  Villegas then brought this appeal anew, contending that the trial court abused its discretion in denying his second motion for new trial.

Motion for New Trial – Default Judgment

In Villegas’s first issue, he contends that the trial court abused its discretion in denying his second and revised second motion for new trial.  Specifically, he argues that he satisfies the criteria for setting aside a default judgment and granting a new trial set out by the Supreme Court of Texas in Craddock because (1) his failure to answer was accidental, (2) he has a meritorious defense, and (3) Morse will not be unduly prejudiced by a new trial.  See Craddock v. Sunshine Bus Lines, Inc., 134 Tex. 388, 133 S.W.2d 124, 126 (1939).

Applicable Law

A trial court’s denial of a motion for new trial is reviewed for abuse of discretion.  Director, State Employees Workers’ Comp. Div. v. Evans, 889 S.W.2d 266, 270 (Tex. 1994); Cliff v. Huggins, 724 S.W.2d 778, 778-79 (Tex. 1987).  An abuse of discretion occurs when a trial court fails to correctly analyze or apply the law.  Walker v. Packer, 827 S.W.2d 833, 839 (Tex. 1992).  In reviewing the judgment of the trial court where there are no findings of fact and conclusions of law filed, the judgment must be upheld on any legal theory that finds support in the evidence.  Lassiter v. Bliss, 559 S.W.2d 353, 358 (Tex. 1977), overruled on other grounds, Cherne Indus., Inc. v. Magallanes, 763 S.W.2d 768 (Tex. 1989).

However, as stated in Craddock "[w]hile trial courts have some measure of discretion in the matter, as, in truth, they have in all cases governed by equitable principles, it is not an unbridled discretion to decide cases as they might deem proper, without reference to any guiding rule or principle."  Craddock, 133 S.W.2d at 126.  Craddock provides that a default judgment should be set aside and a new trial ordered in any case in which: (1) the failure of the defendant to answer before judgment was not intentional, or the result of conscious indifference on his part, but was due to a mistake or an accident; (2) the motion for a new trial sets up a meritorious defense and (3) is filed at a time when the granting thereof will occasion no delay or otherwise work an injury to the plaintiff.  Evans, 889 S.W.2d at 268 (quoting Craddock, 133 S.W.2d at 126).  Thus, a trial court abuses its discretion by not granting a new trial when all three elements of the Craddock test are met.  Bank One, Texas, N.A. v. Moody, 830 S.W.2d 81, 85 (Tex. 1992).

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Related

Jackson v. Mares
802 S.W.2d 48 (Court of Appeals of Texas, 1991)
Young v. Kirsch
814 S.W.2d 77 (Court of Appeals of Texas, 1991)
Lassiter v. Bliss
559 S.W.2d 353 (Texas Supreme Court, 1977)
Holt Atherton Industries, Inc. v. Heine
835 S.W.2d 80 (Texas Supreme Court, 1992)
Freeman v. Pevehouse
79 S.W.3d 637 (Court of Appeals of Texas, 2002)
Ivy v. Carrell
407 S.W.2d 212 (Texas Supreme Court, 1966)
Bank One, Texas, N.A. v. Moody
830 S.W.2d 81 (Texas Supreme Court, 1992)
Comanche Nation v. Fox
128 S.W.3d 745 (Court of Appeals of Texas, 2004)
Walker v. Packer
827 S.W.2d 833 (Texas Supreme Court, 1992)
Angelo v. Champion Restaurant Equipment Co.
713 S.W.2d 96 (Texas Supreme Court, 1986)
Cliff v. Huggins
724 S.W.2d 778 (Texas Supreme Court, 1987)
Cherne Industries, Inc. v. Magallanes
763 S.W.2d 768 (Texas Supreme Court, 1989)
Craddock v. Sunshine Bus Lines, Inc.
133 S.W.2d 124 (Texas Supreme Court, 1939)

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Manuel Villegas v. Heidi Henke Morse, Counsel Stack Legal Research, https://law.counselstack.com/opinion/manuel-villegas-v-heidi-henke-morse-texapp-2008.