Paul Wright and Theresa Wright v. Brandon Liming and Jenna Liming

CourtCourt of Appeals of Texas
DecidedJuly 30, 2019
Docket01-19-00060-CV
StatusPublished

This text of Paul Wright and Theresa Wright v. Brandon Liming and Jenna Liming (Paul Wright and Theresa Wright v. Brandon Liming and Jenna Liming) 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
Paul Wright and Theresa Wright v. Brandon Liming and Jenna Liming, (Tex. Ct. App. 2019).

Opinion

Opinion issued July 30, 2019

In The

Court of Appeals For The

First District of Texas ———————————— NO. 01-19-00060-CV ——————————— PAUL WRIGHT AND THERESA WRIGHT, Appellants V. BRANDON LIMING AND JENNA LIMING, Appellees

On Appeal from the 334th District Court Harris County, Texas Trial Court Case No. 2018-19746

MEMORANDUM OPINION

This is an interlocutory appeal of a temporary injunction that prohibits Paul

and Theresa Wright from trespassing on property owned by their neighbors, Brandon

and Jenna Liming. In two issues, the Wrights contend the trial court abused its discretion in

entering the temporary injunction because the injunction did not meet the

requirements of Civil Procedure Rule 683. Specifically, they contend the injunction

did not adequately describe the acts the Wrights are prohibited from doing or explain

why the Limings do not have an adequate remedy at law. The Wrights contend the

temporary injunction is void due to its deficiencies.

While they disagree with the Wrights’ contention that the temporary

injunction is deficient, the Limings have indicated their agreement to modify the

temporary injunction to add specificity.

Because we conclude any deficiencies in the temporary order can be resolved

through reformation of the order and remand for that purpose would be a less

efficient course, we reform the order and affirm it as reformed.

Background

Randy Darbonne owned several tracts of land in Kingwood, Texas. In 2003,

he began renting a two-tract lot to the Wrights, who later bought the land. In 2017,

he sold another two-tract lot to the Limings. When discussing the features of the

Wrights’ and Limings’ properties and how various people used the properties before

and after the 2017 sale transaction, we will refer to the property the Wrights bought

from Darbonne as D1 and the property the Limings later bought from Darbonne as

D2. See addendum.

2 The D1 and D2 properties share a border. The Wrights’ D1 property has two

houses on it: a “main house” near the roadway and a “back house” deeper onto the

property. The D1 property has two driveways: one driveway goes to the main house,

and the other driveway extends the length of the property alongside both houses.

There is an improved walkway connecting the main house and the back house. The

Limings’ D2 property has only one driveway, which is near the shared border. See

addendum.

Before the Limings moved to Kingwood, Darbonne used the D2 property to

store his boat and various equipment and house a chicken coop. Darbonne did not

live on the property. Darbonne allowed the Wrights to park several trucks and trailers

on the D2 property. Often, the trucks and trailers would straddle the property line

between the two properties. See addendum. Darbonne also allowed the Wrights, their

family members, and their guests to use the D2 driveway to access the back house

on the D1 property.

When Darbonne sold the D2 property to the Limings, he told them the

property came with full title and they could lock the gate and block all access to the

D2 driveway. The Limings paid for a title search as part of their closing. The search

did not reveal any competing ownership interests in the D2 property—the title was

clear.

3 The Limings planned to design and built a custom home on the D2 property.

They met their neighbors, discussed their development plans, and began the

permitting process for construction. During these initial, neighborly encounters, the

Limings told the Wrights that the Wrights needed to remove their vehicles from the

Limings’ property, and the Wrights agreed they would. At times, the Wrights would

remove their trailers and other stored items, but the Wrights never fully remained

off the D2 property.

When the Limings’ fence contractor appeared one day to install a privacy

fence along the property line between D1 and D2, Paul Wright called Brandon

Liming and asked Liming to delay installation a couple days because Wright needed

to move an underground pipe and the fence would be in his way. Liming agreed to

a short delay. Never during this exchange did Wright assert any ownership or

equitable right to the Limings’ land or dispute Limings’ ability to construct a privacy

fence along their shared border. Instead, Wright simply asked that fence construction

be delayed a couple days to allow Wright to move an underground pipe. After Wright

finished moving the pipe, the Limings’ fence contractor returned to build the fence.

When the fence contractor returned, the Wrights’ equipment was still on the

property line, interfering with his ability to install the fence. The contractor

approached the Wrights and asked them to move their vehicles off the property line.

They asked him to “hold on” while someone got “out of the shower” or went to “get

4 the keys.” But they never moved their equipment. After a couple hours of waiting,

the contractor called Liming. Liming arrived, and the Wrights moved their

equipment slightly off the property line. The contractor told Liming the equipment

was still too close to work around and he could not start the installation under those

conditions. The fence would have to be installed later.

Later that day, when one of the Limings’ other contractors left the D2 property

for the day, Liming had the contractor locked the gate. That was the first time the

Limings locked their gate since buying the D2 property.

That evening, Paul Wright called the Limings about the locked gate. Wright

said the locked gate was preventing his guests from leaving the property, meaning

the Wrights’ guests were on the Limings’ property and could not leave through the

Limings’ locked gate. Liming said he would drive over and unlock the gate for them

to leave. Before he got there, the Wrights cut the Limings’ lock, forced open the

Limings’ gate, and drove off the D2 property using the Limings’ driveway.

When he arrived, Brandon Liming questioned the Wrights and their guests

about cutting his lock. According to Liming, one of the Wrights’ guests showed

Liming a Louisiana police badge and told Liming he could not lock the gate to the

driveway because the Wrights have an easement. According to Liming, the Wrights

had never claimed to have an easement or any ownership interest in his property

5 before that night, which was some eight months after the Limings bought the D2

property and began telling the Wrights to remove their vehicles and equipment.

The Limings called their title company about the claimed right to an easement.

The title company looked over the title documents and confirmed title was clear.

When the Wrights cut the Limings’ lock and asserted an easement interest in

the Limings’ property, the Wrights offered to buy a fifteen-feet-wide strip of the

Limings’ property roughly the width of the single driveway on the D2 property. The

Limings did not want to sell any of their land. They rejected the offer.

The Limings asked Darbonne about the Wrights’ claimed right to access.

Darbonne said the Wrights had no right to the D2 property. Darbonne explained he

allowed the Wrights to use the D2 property by permission when he owned it. He did

so for many years, but it was always use by permission. Darbonne said he had

complained to the Wrights a couple times in the past about inconsiderate use of his

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