Marcus Blalock v. Casa Latinas, LLC and Nidia Saldivar

CourtCourt of Appeals of Texas
DecidedNovember 2, 2023
Docket10-23-00134-CV
StatusPublished

This text of Marcus Blalock v. Casa Latinas, LLC and Nidia Saldivar (Marcus Blalock v. Casa Latinas, LLC and Nidia Saldivar) 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
Marcus Blalock v. Casa Latinas, LLC and Nidia Saldivar, (Tex. Ct. App. 2023).

Opinion

IN THE TENTH COURT OF APPEALS

No. 10-23-00134-CV

MARCUS BLALOCK, Appellant v.

CASA LATINAS, LLC AND NIDIA SALDIVAR, Appellees

From the 13th District Court Navarro County, Texas Trial Court No. D22-30215-CV

MEMORANDUM OPINION

Marcus Blalock appeals from a summary judgment rendered against him in his

suit against Casa Latinas, LLC and Nidia Saldivar in a dispute arising from his purchase

of a home. In two issues, Blalock asserts the judgment should be reversed and the cause

remanded because he was fraudulently induced into entering the contract. We affirm. Background

Blalock purchased a home from Appellees in April 2020. Thereafter, he

experienced numerous problems with the home. Alleging that Appellees made multiple

misrepresentations and failed to disclose defects in the home, he sued them for violations

of the Texas Deceptive Trade Practices Act (DTPA) and fraud in connection with a real

estate transaction pursuant to Chapter 27 of the Texas Business and Commerce Code.

Appellees filed a traditional motion for summary judgment asserting there is no

genuine issue of material fact as to the causation element of Blalock's DTPA and statutory

fraud causes of action because the "as is" clause in the sales contract negates that element.

Further, they asserted that there is no genuine issue of material fact as to any exception

that would negate the application of the "as is" clause. The trial court granted the motion

and ordered that Blalock take nothing from Appellees.

The As Is Clause

In his first issue, Blalock contends Appellees fraudulently induced him into

purchasing the residence by concealing material information concerning the condition

and circumstances of the home. He contends Appellees knew there were deficiencies in

the plumbing and electrical systems which they failed to disclose. He also asserts they

failed to disclose that a room had been added to the residence after construction of the

home was completed and that the residence had been occupied before Blalock entered

into the contract to purchase it.

Blalock v. Casa Latinas, LLC Page 2 In his second issue, Blalock contends the contract's "as is" clause is not binding on

him because it is a product of fraud. He asserts that he was induced to enter the

agreement by Appellees' fraudulent misrepresentations and failure to disclose required

material information. He further argues that the totality of the circumstances

surrounding the purchase of the residence precludes binding him to the "as is" clause.

He claims that Appellees were more sophisticated in real estate transactions than he was,

and the "as is" clause was just boiler plate language in a standard form purchase

agreement that could not have been negotiated.

STANDARD OF REVIEW

We review the trial court's decision to grant summary judgment de novo. Eagle

Oil & Gas Co. v. TRO-X, L.P., 619 S.W.3d 699, 705 (Tex. 2021). The movant for traditional

summary judgment has the burden of showing that there is no genuine issue of material

fact, and it is entitled to judgment as a matter of law. TEX. R. CIV. P. 166a(c); Eagle Oil &

Gas Co., 619 S.W.3d at 705. A defendant who conclusively negates at least one of the

essential elements of the cause of action or conclusively establishes an affirmative defense

is entitled to summary judgment. Frost Nat'l Bank v. Fernandez, 315 S.W.3d 494, 508 (Tex.

2010). Once the movant establishes its right to summary judgment as a matter of law, the

burden shifts to the nonmovant to present evidence sufficient to raise a genuine issue of

material fact, thereby precluding summary judgment. Lujan v. Navistar, Inc., 555 S.W.3d

79, 84 (Tex. 2018).

Blalock v. Casa Latinas, LLC Page 3 To determine if the nonmovant has raised a fact issue, we review the evidence in

the light most favorable to the nonmovant, crediting evidence favorable to that party if

reasonable jurors could, and disregarding contrary evidence unless reasonable jurors

could not. B.C. v. Steak N Shake Operations, Inc., 512 S.W.3d 276, 279 (Tex. 2017). We

indulge every reasonable inference in favor of the nonmovant and resolve any doubts in

his favor. Eagle Oil & Gas Co., 619 S.W.3d at 705. The evidence raises a genuine issue of

fact if reasonable and fair-minded jurors could differ in their conclusions in light of all

the summary judgment evidence. Goodyear Tire & Rubber Co. v. Mayes, 236 S.W.3d 754,

755 (Tex. 2007) (per curiam).

ANALYSIS

Causation

In their motion, Appellees asserted that they carried their initial summary

judgment burden by producing evidence that Blalock purchased the property subject to

an "as is" clause in the contract, which negates the causation element of all of Blalock's

claims. Under paragraph 7D(1) of the parties' contract, Blalock agreed to accept the

property "as is." Paragraph 7D provides:

ACCEPTANCE OF PROPERTY CONDITION: "As is" means the present condition of the Property with any and all defects and without warranty except for the warranties of title and the warranties in this contract. Buyer's agreement to accept the Property As Is under Paragraph 7D(1) or (2) does not preclude Buyer from inspecting the Property under Paragraph 7A, from negotiating repairs or treatments in a subsequent amendment, or from terminating this contract during the Option Period, if any. (Check one box only)

Blalock v. Casa Latinas, LLC Page 4 [X] (1) Buyer accepts the Property As Is. [ ] (2) Buyer accepts the Property As Is provided Seller, at Seller's expense, shall complete the following specific repairs and treatments:______________________________________________________ (Do not insert general phrases, such as "subject to inspections" that do not identify specific repairs and treatments.)

Buyers who contract to purchase something "as is" agree to make their own

appraisal of the bargain and to accept the risk that they may be wrong. Prudential Ins. Co.

of Am. v. Jefferson Assocs., Ltd., 896 S.W.2d 156, 161 (Tex. 1995). Generally, an "as is"

agreement negates the causation essential to recovery for a DTPA violation and fraud.

See id. The sole cause of a buyer's injury in such circumstances is the buyer himself. Id.

Accordingly, because the parties' contract contains an "as is" clause, Appellees showed

entitlement to summary judgment by conclusively negating the causation element of

Blalock's claims. See Fernandez, 315 S.W.3d at 508. The burden then shifted to Blalock to

raise a genuine issue of fact precluding summary judgment. See Lujan, 555 S.W.3d at 84.

Exceptions

1. Circumstances

Blalock contends the "as is" clause is not binding. The Prudential court identified

exceptions to the enforcement of an "as is" clause. See Prudential, 896 S.W.2d at 162.

When determining the enforceability of an "as is" clause, we examine the nature of the

transaction and totality of the circumstances. See id. Blalock contends he lacked

sophistication in real estate matters. Blalock was a first-time home buyer, while

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Goodyear Tire and Rubber Co. v. Mayes
236 S.W.3d 754 (Texas Supreme Court, 2007)
Frost National Bank v. Fernandez
315 S.W.3d 494 (Texas Supreme Court, 2010)
Larsen v. Carlene Langford & Associates, Inc.
41 S.W.3d 245 (Court of Appeals of Texas, 2001)
Bradford v. Vento
48 S.W.3d 749 (Texas Supreme Court, 2001)
National Property Holdings, L.P. v. Westergren
453 S.W.3d 419 (Texas Supreme Court, 2015)
B.C. v. Steak N Shake Operations, Inc.
512 S.W.3d 276 (Texas Supreme Court, 2017)
Jpmorgan Chase Bank, N.A. v. Orca Assets G.P., L. L.C.
546 S.W.3d 648 (Texas Supreme Court, 2018)
Lujan v. Navistar, Inc.
555 S.W.3d 79 (Texas Supreme Court, 2018)
Van Duren v. Chife
569 S.W.3d 176 (Court of Appeals of Texas, 2018)
Int'l Bus. Machs. Corp. v. Lufkin Indus., LLC
573 S.W.3d 224 (Texas Supreme Court, 2019)

Cite This Page — Counsel Stack

Bluebook (online)
Marcus Blalock v. Casa Latinas, LLC and Nidia Saldivar, Counsel Stack Legal Research, https://law.counselstack.com/opinion/marcus-blalock-v-casa-latinas-llc-and-nidia-saldivar-texapp-2023.