Marcie McCarthy v. Wani Venture, AS

CourtCourt of Appeals of Texas
DecidedJune 28, 2007
Docket01-04-00921-CV
StatusPublished

This text of Marcie McCarthy v. Wani Venture, AS (Marcie McCarthy v. Wani Venture, AS) 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
Marcie McCarthy v. Wani Venture, AS, (Tex. Ct. App. 2007).

Opinion

Opinion issued June 28, 2007



In The

Court of Appeals

For The

First District of Texas



NO. 01-04-00921-CV

__________



MARCIE M. MCCARTHY, Appellant



V.



WANI VENTURE, A.S.,

SUCCESSOR IN INTEREST TO

NORGIPS USA, INC., Appellee



On Appeal from the 129th District Court

Harris County, Texas

Trial Court Cause No. 2001-21419



DISSENTING OPINION

Because the majority errs in concluding that the evidence is legally sufficient to support the jury's finding that appellant, Marcie McCarthy, primarily for her own direct personal benefit, caused Triple M Supply, LLC ("TMS") to be used to perpetrate an actual fraud, and did perpetrate an actual fraud upon appellee, Wani Venture, A.S., as successor in interest to Norgips USA, Inc. (collectively "Norgips"), I respectfully dissent.

In her fourth issue, McCarthy argues that the trial court erred in entering judgment against her because there is no evidence that she was a substantial factor in causing Norgips's injury, that she caused TMS to be used to perpetrate a fraud, and that a fraud was committed "primarily for her own direct personal benefit." In sum, she contends that there is no evidence that she "knew of any alleged 'fraudulent scheme,' much less being a substantial factor, in bringing about the injury to Norgips, or that money [she] received was related to any fraudulent scheme."

Standard of Review

We must sustain a legal sufficiency or "no-evidence" challenge if the record shows one of the following: (1) a complete absence of evidence of a vital fact, (2) rules of law or evidence bar the court from giving weight to the only evidence offered to prove a vital fact, (3) the evidence offered to prove a vital fact is no more than a scintilla, or (4) the evidence establishes conclusively the opposite of the vital fact. City of Keller v. Wilson, 168 S.W.3d 802, 810 (Tex. 2005). Evidence does not exceed a scintilla if it does no more than create a mere surmise or suspicion that a fact exists. Ford Motor Co. v. Ridgway, 135 S.W.3d 598, 601 (Tex. 2004). If the evidence at trial would enable reasonable and fair-minded people to differ in their conclusions, then jurors must be allowed to do so. City of Keller, 168 S.W.3d at 822. In conducting a legal sufficiency review of the evidence, a court must consider all of the evidence in the light most favorable to the verdict and indulge every reasonable inference that would support it. Id.

As further explained by the Texas Supreme Court,

The evidence presented, viewed in the light most favorable to the prevailing party, must be such as to permit the logical inference [that the jury must reach]. There must necessarily be a logical connection, direct or inferential, between the evidence offered and the fact to be proved. However, we must also bear in mind the difference between materiality of the evidence and the issue of evidentiary sufficiency. Simply because a piece or pieces of evidence are material in the sense that they make a "fact that is of consequence to the determination of the action more . . . or less probable," does not render the evidence legally sufficient.



Transp. Ins. Co. v. Moriel, 879 S.W.2d 10, 24-25 (Tex. 1994) (citations omitted). As Professor McCormick emphasized, "a brick is not a wall." Id. (quoting Charles T. McCormick, Handbook of the Law of Evidence § 152 (West ed. 1954)).

Actual Fraud

Generally, under Texas law, shareholders are not liable for the debts of a corporation; however, Texas courts will pierce the corporate veil to prevent fraud or to achieve equity. Castleberry v. Branscum, 721 S.W.2d 270, 271-72 (Tex. 1987). In particular, courts will disregard the corporate fiction when individuals exploit the corporate form as a sham to perpetrate a fraud. Id. at 272. In response to Castleberry, the Texas Legislature amended article 2.21 of the Texas Business Corporations Act in 1989 to establish "a clear legislative standard under which the liability of a shareholder for the obligations of a corporation is to be determined in the context of contractual obligations and all matters relating thereto." Tex. Bus. Corp. Act Ann. art 2.21, Comment of Bar Committee--1996 (Vernon 2003).

Under article 2.21A, a shareholder has no obligation to the obligees of a corporation regarding any contractual obligation of the corporation on the basis of actual or constructive fraud or a sham to perpetrate a fraud, "unless the obligee demonstrates that the [shareholder] . . . caused the corporation to be used for the purpose of perpetuating and did perpetrate an actual fraud on the obligee primarily for the direct personal benefit of the [shareholder] . . . ." Id. art. 2.21A(2) (emphasis added). Actual fraud occurs when: a. a party conceals or fails to disclose a material fact within the knowledge of that party,



b. the party knows that the other party is ignorant of the fact and does not have an equal opportunity to discover the truth,



c. the party intends to induce the other party to take some action by concealing or failing to disclose the fact, and



d. the other party suffers injury as a result of acting without knowledge of the undisclosed fact.



Bradford v. Vento, 48 S.W.3d 749, 754-55 (Tex. 2001). The test for cause in fact is whether an "act or omission was a substantial factor in bringing about injury," without which the harm would not have occurred. Doe v. Boys Clubs of Greater Dallas, Inc., 907 S.W.2d 472, 477 (Tex. 1995).

In accordance with article 2.21A(2) and case law, the trial court instructed the jury on actual fraud and to answer the following question:

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Related

Ford Motor Co. v. Ridgway
135 S.W.3d 598 (Texas Supreme Court, 2004)
Doe v. Boys Clubs of Greater Dallas, Inc.
907 S.W.2d 472 (Texas Supreme Court, 1995)
Transportation Insurance Co. v. Moriel
879 S.W.2d 10 (Texas Supreme Court, 1994)
City of Keller v. Wilson
168 S.W.3d 802 (Texas Supreme Court, 2005)
Bradford v. Vento
48 S.W.3d 749 (Texas Supreme Court, 2001)
Castleberry v. Branscum
721 S.W.2d 270 (Texas Supreme Court, 1986)

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Bluebook (online)
Marcie McCarthy v. Wani Venture, AS, Counsel Stack Legal Research, https://law.counselstack.com/opinion/marcie-mccarthy-v-wani-venture-as-texapp-2007.