Maria Reva West Prado v. Maria De Lourdes Ayala Leal

CourtCourt of Appeals of Texas
DecidedOctober 22, 2020
Docket09-19-00154-CV
StatusPublished

This text of Maria Reva West Prado v. Maria De Lourdes Ayala Leal (Maria Reva West Prado v. Maria De Lourdes Ayala Leal) 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
Maria Reva West Prado v. Maria De Lourdes Ayala Leal, (Tex. Ct. App. 2020).

Opinion

In The

Court of Appeals

Ninth District of Texas at Beaumont

__________________

NO. 09-19-00154-CV __________________

MARIA REVA WEST PRADO, Appellant

V.

MARIA DE LOURDES AYALA LEAL, Appellee

__________________________________________________________________

On Appeal from the 284th District Court Montgomery County, Texas Trial Cause No. 16-12-13925-CV __________________________________________________________________

MEMORANDUM OPINION

In two issues on appeal, appellant María Reva West Prado (“West Prado”)

complains that the trial court erred by denying her Rule 12 motion to show authority

and her motion to stay. For the reasons explained herein, the trial court’s judgment

is affirmed in part, vacated in part, and remanded.

Background

Banorte-Ixe Securities International, Ltd. (“Banorte”), a broker-dealer

registered with the U.S. Securities and Exchange Commission and a member of The

1 Financial Industry Regulatory Authority, Inc., filed a petition in interpleader against

West Prado and María de Lourdes Ayala Leal (“Leal”), who are both individuals

residing in Mexico. The interpleader concerns a dispute over a Banorte account

jointly owned by Augustina Prado Díaz (“Augustina”) and West Prado, Augustina’s

niece, which is a multiple-party account with right of survivorship and transfer on

death (“TOD”) designations, and the TOD beneficiaries are Jose Luis Prado Díaz

(“Prado Díaz”), Luciel West Prado, and West Prado. In 1998, West Prado and

Augustina opened a joint brokerage account with Banorte’s predecessor (the “Joint

Account”) in Laredo, Texas, agreeing to submit to personal jurisdiction of the courts

of the State of Texas. As of September 2016, the Joint Account held approximately

$3,289,000.

In its petition, Banorte stated that in July 2015, it received, through the United

States Department of Justice, a letter rogatory seeking documents in connection with

an involuntary guardianship proceeding against Augustina in Nuevo León, Mexico,

which Leal and Prado Díaz, Augustina’s brother, initiated. In February 2016,

Banorte received a letter from Prado Díaz and Leal, who claimed to be the court-

appointed legal guardians of Augustina, demanding the transfer of $2,900,000 from

the Joint Account to a bank in Monterrey, Nuevo León, Mexico. According to

Banorte’s petition, it was unable to determine whether Prado Díaz and Leal had legal

authority to act on Augustina’s behalf and to withdraw or transfer funds from the

2 Joint Account, because Prado Díaz and Leal had not sought or obtained an order

from a court of competent jurisdiction in Texas concerning the ownership of the

Joint Account or their authority to direct transactions in the Joint Account. In

February 2016, Banorte froze the funds in the Joint Account and informed Prado

Díaz and Leal that it would not transfer funds from the Joint Account without written

instructions signed by both account holders or their legal representatives or a court

order by a court in the United States.

In March 2016, Banorte received a letter from West Prado’s Texas counsel

explaining that West Prado was contesting Prado Diaz’s guardianship of Augustina

and demanding that Banorte not transfer any funds held in the Joint Account.

Banorte’s petition indicates that West Prado provided Mexican court documents

showing that she had commenced an amparo proceeding in Mexico to set aside the

appointment of Prado Díaz and Leal as Augustina’s legal guardians due to a lack of

summons. According to the documents Prado West provided, the First District Judge

for Civil and Labor Matters in the State of Nuevo León sustained West Prado’s

amparo complaint and Augustina’s guardianship was under review.

In September 2016, Banorte received a letter from Kevin Duddlesten of

McGuire Woods on behalf of Prado Díaz, asserting that Prado Díaz was Augustina’s

guardian and instructing Banorte that no transactions should be allowed on the Joint

Account without notice and consent by Prado Díaz. According to Banorte’s petition,

3 in November 2016, Prado Díaz’s counsel from Monterrey, Mexico, sent an email

reiterating that Prado Díaz was Augustina’s guardian, but counsel also

acknowledged that final judgment was pending because West Prado had filed a

constitutional relief action challenging Prado Díaz’s appointment. The record shows

that the First Collegiate Court of Appeals in Civil Matters for the Fourth Circuit of

Mexico (“the Mexican Appeals Court”) found that West Prado’s constitutional relief

action had merit and ordered the First Family Court of the Fourth Judicial District

of Nuevo Leon (“the Mexican Court”) to vacate the judgment finding Augustina

incompetent and appointing Prado Diaz as the guardian of her person and estate.

The Mexican Court vacated its prior judgment and entered a judgment appointing

Leal as guardian of Augustina’s person and estate.

Due to the ongoing dispute between West Prado and Prado Díaz regarding the

right to control the Joint Account, Banorte filed an interpleader, alleging that it was

unable to determine who is entitled to the funds in the Joint Account and offering to

deposit the funds into the Court’s registry to avoid multiple liability and incidental

costs. Banorte requested to be released and discharged from all liability on the Joint

Account and to recover reasonable attorney’s fees and costs. Banorte deposited

$3,627,770.86 from its law firm’s IOLTA account into the Court’s registry. In June

2017, the trial court discharged Banorte and granted Banorte reasonable and

necessary attorney’s fees and costs.

4 In June 2018, Leal filed an amended answer to Banorte’s petition in

interpleader, asserting that the Joint Account is held by Augustina and West Prado

as tenants in common and that each of their interests in the Joint Account is based

on their relative contributions to the Joint Account. According to Leal, Augustina

contributed approximately ninety percent of the funds into the Joint Account and

that any claims of control or entitlement to the funds in the Joint Account by West

Prado are barred, in whole or in part, by equitable doctrines. As Augustina’s

guardian, Leal requested that Augustina recover ninety percent of the monies in the

Joint Account, which is the value proportionate to the aggregate contributions

Augustina made to the Joint Account. Leal also filed a motion to substitute Prado

Díaz as Augustina’s temporary guardian, because upon review, the Mexican Court

determined that Prado Díaz should continue to serve as Augustina’s temporary

guardian.

In November 2018, West Prado filed a Rule 12 motion to show authority

under the Texas Rules of Civil Procedure, arguing that Duddlesten did not have

proper authority to represent Augustina’s interests. According to West Prado,

Duddlesten did not have authority to file an answer on behalf of Augustina or Leal,

who was acting in her capacity as supervisor to guardian Prado Díaz. West Prado

argued that under Texas law, the Mexican Court has the sole authority to determine

the rights of the guardian in a case involving Texas domestic assets, and the Mexican

5 Court had not given Leal the authority to transfer Augustina’s funds from the Joint

Account. West Prado requested that the court deny Duddlesten permission to

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