Patricia Hayes Donalson, Independent of the Estate of George E. Hayes v. Jerry Harrington, Individually and as Independent of the Estate of Betty Jo Hayes

CourtCourt of Appeals of Texas
DecidedJuly 29, 2021
Docket09-19-00286-CV
StatusPublished

This text of Patricia Hayes Donalson, Independent of the Estate of George E. Hayes v. Jerry Harrington, Individually and as Independent of the Estate of Betty Jo Hayes (Patricia Hayes Donalson, Independent of the Estate of George E. Hayes v. Jerry Harrington, Individually and as Independent of the Estate of Betty Jo Hayes) 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.

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Patricia Hayes Donalson, Independent of the Estate of George E. Hayes v. Jerry Harrington, Individually and as Independent of the Estate of Betty Jo Hayes, (Tex. Ct. App. 2021).

Opinion

In The

Court of Appeals

Ninth District of Texas at Beaumont

________________

NO. 09-19-00286-CV ________________

PATRICIA HAYES DONALSON, INDEPENDENT EXECUTRIX OF THE ESTATE OF GEORGE E. HAYES, Appellant

V.

JERRY HARRINGTON, INDIVIDUALLY AND AS INDEPENDENT EXECUTOR OF THE ESTATE OF BETTY JO HAYES, Appellee ________________________________________________________________________

On Appeal from the County Court at Law No. 1 Jefferson County, Texas Trial Cause No. 117707 ________________________________________________________________________

MEMORANDUM OPINION

Patricia Hayes Donalson appeals the trial court’s final judgment based on a

jury verdict in favor of Jerry Harrington. 1 In three issues, Donalson argues: (1)

Harrington is not entitled to attorney’s fees both as a matter of law and based on a

1 Jerry Harrington passed away during the pendency of this appeal. The appeal was abated, and the trial court appointed Thomas Amidee Morgan as the successor executor of Betty Jo Hayes’s estate. 1 lack of evidence at trial; (2) there is legally and factually insufficient evidence to

support the jury’s findings of zero damages for Harrington’s breach of fiduciary

duty; and (3) there is legally and factually insufficient evidence to support the jury’s

finding of estoppel and ratification as affirmative defenses to Harrington’s breach of

fiduciary duty. Harrington also raises one cross-point on appeal, challenging the

jury’s breach of fiduciary duty findings. For the following reasons, we affirm the

trial court’s judgment.

Background

The underlying litigation involves a suit for declaratory judgment and will

contest. In 1998, Betty Jo drafted a will leaving everything to her husband, George.

In the event that George predeceased her, half of Betty’s property would go to her

only living son, Harrington, and the other half would go to George’s sister,

Donalson. On November 15, 2016, Betty Jo executed another will, leaving her entire

estate to Harrington. At the time Betty Jo executed this will, the record showed she

suffered from many health problems, including the early stages of Alzheimer’s.

According to Harrington, Betty Jo wanted to execute a new will, so he found

her a lawyer. Harrington testified that he drove Betty Jo to the lawyer’s office, and

he characterized her mental state as “good” when he took her to execute the will.

Harrington did not tell George that Betty Jo executed a new will. The attorney who

prepared the will also testified at trial. The attorney stated that she visited with Betty

2 Jo before drafting the will and believed Betty Jo understood what she was signing

and where her property was going. The attorney also testified that based on her

observation, Harrington was not trying to get his mother to sign a will in his favor

and in fact, cautioned her to make certain she wanted to do it before she signed. The

attorney also explained that Betty Jo directed all her property to go to Harrington

instead of George, and Betty Jo “was very clear in her intent[.]”

Betty Jo died on May 4, 2017. Thereafter, Harrington applied to probate the

new will and obtain the issuance of letters testamentary. Harrington also filed a

declaratory judgment action against George, seeking to have the Hayses’ bank

accounts, IRA accounts, and home declared community property, with one-half

belonging to Betty Jo. Harrington also sought injunctive relief to prevent George

from spending or transferring the property. Harrington sought attorney’s fees

pursuant to Texas Civil Practice and Remedies Code section 37.009 and Texas

Probate Code section 352.052.

George died before trial; his sister and sole heir, Donalson, was named

executrix of his estate. Donalson had also been named as the successor executrix

under Betty Jo’s 1998 will and a contingent beneficiary if George predeceased Betty

Jo. Donalson counterclaimed for declaratory judgment that Harrington committed

fraud and depleted the community estate and sought damages for breach of fiduciary

duty. She also filed a separate opposition seeking to invalidate the November 2016

3 will and to instead have the 1998 will admitted to probate. Prior to trial, Harrington

filed a no evidence motion for summary judgment on his declaratory judgment

action to have the specified property declared community property, which the trial

court granted.

When Betty Jo died, Harrington was her only living child and George’s

stepson. George and Betty Jo had been married since the late 1970s. George retired

from Gulf States, while Betty Jo retired from Texaco. They also received Social

Security benefits. Both George and Betty Jo suffered from numerous health

problems. Neither of them could drive, and they required assistance from home

health nurses that came into the home multiple times a week. Harrington saw Betty

Jo every day and despite Betty Jo’s health problems, he did not believe there was

anything wrong with her mentally, but he occasionally reported to doctors she was

confused.

Despite not working for more than eight years, Harrington testified he

obtained employment on a construction job but did not take it so he could take care

of George and Betty Jo, which was what George wanted. Harrington testified that

he took them to see doctors, picked up medications for them, mowed their grass, and

bought groceries for them. He testified that his monthly bills were $1900, and that

was what George paid him per month. The evidence also established that George

4 would sign blank checks and give them to Harrington to fill out. There was also

testimony at trial that George paid for some home repairs to Harrington’s house.

The trial court submitted thirteen issues to the jury. The jury found that Betty

Jo had testamentary capacity to execute the November 2016 will and Harrington had

not unduly influenced her to execute the will. The jury found that a relationship of

trust and confidence existed between George and Betty Jo and Harrington and that

Harrington failed to comply with that relationship. The jury found that when George

signed the blank checks, he did not have full knowledge of all material facts related

to the breach of fiduciary duty. However, the jury also found that George ratified

Harrington’s conduct after he did obtain full knowledge of the facts and that his

estate was estopped from seeking any damages. The jury found that Harrington acted

in good faith in defending the November 2016 will but found that Donalson did not

act in good faith and with just cause in prosecuting the suit to have the 1998 will

admitted to probate. The jury awarded Donalson zero damages for Harrington’s

breach of fiduciary duty. The jury also awarded Harrington $32,244 in necessary

expenditures, including reasonable attorney’s fees, which the trial court reduced to

$21,150 in the final judgment.

5 General Rules of Error Preservation

In response to each of Donalson’s issues, Harrington argues that she failed to

preserve these complaints for our review. 2 As a prerequisite to presenting a

complaint on appeal, an appellant must show she preserved it by making the

complaint “to the trial court by a timely request, objection, or motion” stating the

grounds for the desired ruling with “sufficient specificity to make the trial court

aware of the complaint, unless the specific grounds were apparent from the

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Patricia Hayes Donalson, Independent of the Estate of George E. Hayes v. Jerry Harrington, Individually and as Independent of the Estate of Betty Jo Hayes, Counsel Stack Legal Research, https://law.counselstack.com/opinion/patricia-hayes-donalson-independent-of-the-estate-of-george-e-hayes-v-texapp-2021.