Maternidad De Los Santos v. Martha Gonzalez A/N/F of Eduardo A. Gonzalez,a Minor Child

CourtCourt of Appeals of Texas
DecidedApril 12, 2000
Docket04-99-00130-CV
StatusPublished

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Maternidad De Los Santos v. Martha Gonzalez A/N/F of Eduardo A. Gonzalez,a Minor Child, (Tex. Ct. App. 2000).

Opinion

No. 04-99-00130-CV
MATERNIDAD DE LOS SANTOS,
Appellant
v.
Martha GONZALEZ, As Next Friend of Eduardo Gonzalez, A Minor Child,
Appellee
From the 365th Judicial District Court, Maverick County, Texas
Trial Court No. 97-06-14587-CV-A
Honorable Amado Abascal III, Judge Presiding

Opinion by: Alma L. López, Justice

Sitting: Phil Hardberger, Chief Justice

Tom Rickhoff, Justice

Alma L. López, Justice

Delivered and Filed: April 12, 2000

REVERSED AND REMANDED

This appeal arises from the denial of a motion for new trial and to set aside a default judgment. Martha Gonzalez, as next friend of Eduardo Gonzalez, a minor child, filed an original petition alleging medical malpractice while under the care of Ramiro de los Santos, M.D. of Maternidad de los Santos ("Maternidad") for the delivery of her new born child, Eduardo Gonzalez. The trial court rendered a default judgment in favor of Gonzalez upon the failure of Maternidad to answer following service of process. In a single issue on appeal, Maternidad contends that the trial court abused its discretion in denying the motion for new trial. We reverse the judgment of the trial court and remand the case for trial.

Factual and Procedural Background

Martha Gonzalez gave birth to Eduardo Gonzalez on May 5, 1985. At the time of his birth, Eduardo received a permanent birth injury called Erb's Palsy, which incapacitated his arm. Martha filed an original petition on June 25, 1997 against Dr. Ramiro de los Santos and his clinic, Maternidad de los Santos. On June 26, 1997, de los Santos was served with two citations, one for himself and one for Maternidad, of which he is an agent. Dr. de los Santos filed an answer on July 18, 1997. On September 9, 1998, more than a year later, the trial court entered a default judgment against Maternidad for $2,100,000. Subsequently, Maternidad filed an original answer and a motion for new trial on September 24, 1998. On November 24, 1998, the trial court denied the motion for new trial and ordered a severance.(1) On November 30, 1998, Maternidad requested findings of facts and conclusions of law from the court. Maternidad filed a second motion for new trial on December 22, 1998,(2) which was overruled as a matter of law. On January 12, 1999, the trial court filed findings of fact and conclusions of law.

On appeal, Maternidad complains that the default judgment should have been set aside and a new trial granted because its failure to file an answer was due to accident or mistake and not conscious indifference; further, Maternidad contends that it demonstrated a meritorious defense and established that the granting of a new trial would not delay the proceeding or injure the plaintiff.

Motion for New Trial

To determine whether the trial court erred by failing to set aside the default judgment, we must assess whether the trial court abused its discretion. See Strackbein v. Prewitt, 671 S.W.2d 37, 38 (Tex. 1984). A trial court has wide discretion in granting a new trial, and the trial court's discretion will not be disturbed on appeal absent a showing of a manifest abuse of discretion. See Champion Int'l Corp. v. Twelfth Court of Appeals, 762 S.W.2d 898, 899 (Tex. 1988). A trial court abuses its discretion if its decision is arbitrary, unreasonable, and without reference to any guiding rules and principles. See Goode v. Shoukfeh, 943 S.W.2d 441, 446 (Tex. 1997).

Whether the trial court should grant a motion for new trial to set aside a proper default judgment is determined by using the standard set out in Craddock v. Sunshine Bus Lines, Inc., 134 Tex. 388, 393, 133 S.W.2d 124, 126 (Tex. Com. App. 1939). See Holt Atherton Industries, Inc. v. Heine, 835 S.W.2d 80, 82 (Tex. 1992) (reaffirming the Craddock test). Under this standard, a trial court may set aside a default judgment and order a new trial 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) provided that the motion for 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. See Craddock,133 S.W.2d at 126. If the facts underlying the default judgment are disputed, the trial court may, but is not required to, make findings in support of its ruling. See Landon v. Jean-Paul Budinger, Inc., 724 S.W.2d 931, 940 (Tex. App.--Austin 1987, no writ).

In making its determination, the trial court should exercise liberality in favor of a defaulted party. See Sexton v. Sexton, 737 S.W.2d 131, 133 (Tex. App.--San Antonio 1987, no writ). When a defendant satisfies the Craddock test, the trial court must set aside the default judgment. See Director, State Employees Workers' Compensation Div. v. Evans, 889 S.W.2d 266, 268 (Tex. 1994). When the guidelines of Craddock are satisfied, it is an abuse of discretion to deny the defendant a new trial. See id.

1. Conscious Indifference

To begin the analysis, we must first determine whether Maternidad established that its failure to answer was due to a mistake or accident rather than the result of conscious indifference. See Craddock, 133 S.W.2d at 126. Conscious indifference exists when the defaulted party fails to take some action which would seem obvious to a reasonable person in the same or similar circumstances. See Norton v. Martinez, 935 S.W.2d 898, 901 (Tex. App.--San Antonio 1996, no writ).

The defaulting party must provide some excuse, but not necessarily a good excuse for failing to answer in a timely manner. See Norton, 935 S.W.2d at 901; Gotcher v. Barnett, 757 S.W.2d 398, 401 (Tex. App.--Houston [14th Dist.] 1988, no writ) (finding that "even a slight excuse will suffice"). The absence of a purposeful or bad faith failure to answer is the controlling factor under this analysis. See Craddock, 133 S.W.2d at 125.

Moreover, when a defendant relies on his agent to file an answer, he must demonstrate that both he and his agent were free of conscious indifference. See Holt Atherton Industries, 835 S.W.2d at 83. Because de los Santos was Maternidad's agent, Maternidad must show that de los Santos's failure to answer was due to a mistake or accident rather than intentional or due to conscious indifference. See id.

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Maternidad De Los Santos v. Martha Gonzalez A/N/F of Eduardo A. Gonzalez,a Minor Child, Counsel Stack Legal Research, https://law.counselstack.com/opinion/maternidad-de-los-santos-v-martha-gonzalez-anf-of-eduardo-a-gonzaleza-texapp-2000.