Pablo Tello v. Bank One, N.A.: Banc One Texas Leasing Corp

CourtCourt of Appeals of Texas
DecidedJanuary 9, 2007
Docket14-04-00888-CV
StatusPublished

This text of Pablo Tello v. Bank One, N.A.: Banc One Texas Leasing Corp (Pablo Tello v. Bank One, N.A.: Banc One Texas Leasing Corp) 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
Pablo Tello v. Bank One, N.A.: Banc One Texas Leasing Corp, (Tex. Ct. App. 2007).

Opinion

Affirmed and Majority and Dissenting Opinions filed January 9, 2007

Affirmed and Majority and Dissenting Opinions filed January 9, 2007.

In The

Fourteenth Court of Appeals

_______________

NO. 14-04-00888-CV

PABLO TELLO, Appellant

V.

BANK ONE, N.A. and BANC ONE ACCEPTANCE CORP., Appellees

On Appeal from the County Civil Court at Law No. 2

Harris County, Texas

Trial Court Cause No. 786,601

 D I S S E N T I N G  O P I N I O N


Appellees Bank One, N.A. (ALienholder@) and Banc One Acceptance Corporation (AAssignee@) filed suit against appellant Pablo Tello to recover sums they claim were owing under the lease agreement; however, they attached only part of the lease agreement to their pleadings, and when they moved for summary judgment in the trial court, they made the same mistake.  Consequently, our appellate record contains only part of the contract upon which the trial court=s summary judgment is based.  As explained in more detail below, this omission is significant because to recover damages for breach of a contract as a matter of law, the movant must establish the amount of damages flowing from the breach. In this case, the part of the lease agreement omitted from our record contains terms regarding early termination of the lease, any security interest in the vehicle, and  default charges C parts that would show how much Tello would owe if he terminated the lease before the end of its term and how much the Lienholder and the Assignee (hereinafter collectively ABank One Entities@) would be entitled to recover for breach of the lease agreement.  Moreover, because the Assignee does not have the vehicle and has no way of knowing the amount of mileage on the vehicle, it is not possible to calculate any applicable mileage penalty, a data point necessary to determine the amount ostensibly due under the lease.  Based on the portions of the lease that are in the summary-judgment evidence, Tello owes only a fraction of the amount the trial court awarded in actual damages.

In his appellate brief, Tello asserts that the trial court erred in granting summary judgment as to the amount of contract damages for which he is liable.  Construing Tello=s brief liberally, as this court must, Tello argues that the traditional summary-judgment motion and attached evidence did not prove the lack of a genuine issue of fact and that the Bank One Entities are entitled to judgment as a matter of law for the damages awarded on their contract claim.  This assertion is correct and should be sustained, but rather than reaching the merits of Tello=s winning argument, the court erroneously concludes that Tello should lose based on a failure to preserve error. 


According to the majority, Tello did not expressly present his sixth issue to the trial court, thereby waiving this issue.  This analysis is based on the majority=s conclusion that Tello=s argument is not an attack on the sufficiency of the summary-judgment motion, a point that need not be raised in the trial court to be asserted on appeal.  This conclusion is incorrect because, under a liberal construction, Tello=s argument under his sixth issue challenges the sufficiency of the Bank One Entities= motion and proof of their entitlement to summary judgment on their contract claim.  Therefore, contrary to the majority=s assertion, this argument did not have to be raised in the trial court.  See Anderson Hosp. and Tumor Inst. v. Willrich, 28 S.W.3d 22, 23 (Tex. 2000) (stating that, as to traditional motions for summary judgment, nonmovant has no duty to respond unless the movant conclusively establishes its claim or defense).  There is no valid basis to find waiver for failure to preserve error in the trial court.

The court also holds that Tello waived this point through inadequate briefing.  This analysis, though a somewhat subjective call, is contrary to the standards the Texas Supreme Court has articulated for disposing of parties= appellate rights without reaching the merits of their appellate points.  Under both the Texas Rules of Appellate Procedure and Texas Supreme Court precedent, this court must construe the briefing rules reasonably, yet liberally. See Tex. R. App. P. 38.1(h), 38.9; Republic Underwriters Ins. Co. v. Mex‑Tex, Inc., 150 S.W.3d 423, 427 (Tex. 2004).  Substantial compliance with the briefing rules may be sufficient, and this court is not required to insist on unerring compliance with them. Bufkin v. State, 179 S.W.3d 166, 174 (Tex. App.CHouston [14th Dist.] 2005), aff=d, No. PD-0012-06, CS.W.3dC, 2006 WL 3077474,  (Tex. Crim. App. Apr. 26, 2006).  Texas courts have embraced this liberal briefing standard largely because the proper objective of a reviewing court is to reach a just, fair, and equitable adjudication of the rights of litigants under established principles of substantive law.  While well-organized and sharply focused writing is always appreciated, that is not the standard by which we determine the legal adequacy of appellate briefs.  The Texas Supreme Court has set a far more forgiving standard, one that requires appellate courts to construe arguments liberally so that parties= poor presentation of their appellate points does not result in a forfeiture of the opportunity for a merits review.


Ideally, an appellant=s brief should contain a clear and concise argument for the contentions made, with appropriate citations to authorities and to the record.  Tex. R. App. P. 38.1(h).  We must interpret this requirement reasonably and liberally.  See Tex. R. App. P. 38.1(h), 38.9; Mex‑Tex, Inc., 150 S.W.3d at 427; see also Tribble & Stephens Co v. RGM Constructors, L.P., 154 S.W.3d 639, 675 (Tex. App.C

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