Peggy S. McElroy v. Unifund CCR Partners Assignee of America Online - Platinum

CourtCourt of Appeals of Texas
DecidedAugust 26, 2008
Docket14-07-00661-CV
StatusPublished

This text of Peggy S. McElroy v. Unifund CCR Partners Assignee of America Online - Platinum (Peggy S. McElroy v. Unifund CCR Partners Assignee of America Online - Platinum) 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
Peggy S. McElroy v. Unifund CCR Partners Assignee of America Online - Platinum, (Tex. Ct. App. 2008).

Opinion

Affirmed and Memorandum Opinion filed August 26, 2008

Affirmed and Memorandum Opinion filed August 26, 2008.

In The

Fourteenth Court of Appeals

____________

NO. 14-07-00661-CV

PEGGY C. McELROY, Appellant

V.

UNIFUND CCR PARTNERS, ASSIGNEE OF AMERICA ONLINE-PLATINUM, Appellee

On Appeal from the County Civil Court at Law No. 4

Harris County, Texas

Trial Court Cause No. 849485

M E M O R A N D U M   O P I N I O N


Peggy C. McElroy appeals a judgment in favor of Unifund CCR Partners for unpaid credit card debt on grounds that (1) Unifund_s business records were improperly admitted into evidence based on an affidavit from a Adesignated agent@ rather than a custodian of records; (2) certain Unifund business records admitted into evidence contained hearsay within hearsay; (3) Unifund failed to establish the existence of a contract with McElroy; and (4) Unifund failed to establish viable claims for breach of contract or quantum meruit.  We affirm.

Background

Unifund CCR Partners sued Peggy C. McElroy to recover unpaid debt on a credit card  account.  The account was originally issued under the creditor name AMERICA ONLINE-PLATINUM and later acquired by Unifund by assignment.  Unifund pleaded both breach of contract and quantum meruit.

The lawsuit was tried to the court on July 5, 2007.  Unifund called no witnesses during the trial on the merits, relying exclusively upon evidence contained within business records provided by Unifund and its assignors to establish McElroy_s liability.  As admitted, these records included a proffering affidavit signed by Unifund employee Angela Freckman; a signature card for the account; an affidavit signed by Robert Watson, an employee of the assignor of the account; and more than a dozen monthly account statements.

The trial court signed a judgment in favor of Unifund for $15,114.66, plus interest and reasonable statutory attorneys fees.  McElroy did not request findings of fact or conclusions of law.  McElroy timely appealed.

Analysis

Admission of Business Records by ADesignated Agent_s@ Affidavit


In her first issue, McElroy contends that the trial court erred in admitting Unifund_s business records into evidence at trial over her hearsay objection.  We review a trial court_s decision to admit or exclude evidence for an abuse of discretion.  In re J.P.B., 180 S.W.3d 570, 575 (Tex. 2005).  A trial court abuses its discretion if its decision is arbitrary, unreasonable, and without reference to guiding principles.  See Owens‑Corning Fiberglas Corp. v. Malone, 972 S.W.2d 35, 43 (Tex. 1998).  An appellate court must uphold the trial court=s evidentiary ruling if there is any legitimate basis for the ruling.  Id.  Moreover, we will not reverse a trial court for an erroneous evidentiary ruling unless the error probably caused the rendition of an improper judgment.  Id.; see also Tex. R. App. P. 44.1.

At trial, Unifund offered for admission selected business records including a proffering affidavit; McElroy_s signature card for the account; an affidavit from Chase Bank, USA employee Robert Watson describing the assignment of McElroy_s account to Unifund and the account status when assigned; 13 monthly statements; and an account statement created by Unifund. McElroy objected to admission of these records as hearsay, but the trial court admitted them under the business records exception to the hearsay rule. See Tex. R. Evid. 803(6).

Specifically, McElroy objects on appeal to the affidavit by which Unifund sought to authenticate its business records under the hearsay exception. See Tex. R. Evid. 902(10).  McElroy argues that the affidavit was insufficient under Rule 902(10) because the affiant, Unifund employee Angela Freckman, identified herself as the Adesignated agent@ of Unifund rather than the Acustodian of records.@  McElroy further asserts that Freckman lacked personal knowledge of the account as required under Rule 803(6).  McElroy argues Freckman was not competent to lay the proper foundation required under Rule 902(10) for the business records to qualify under the Rule 803(6) exception to the hearsay rule.  We reject these contentions.

A_Hearsay_ is a statement, other than one made by the declarant while testifying at the trial or hearing, offered in evidence to prove the truth of the matter asserted.@  Tex. R. Evid. 801(d).  The proponent of hearsay has the burden of showing that the testimony fits within an exception to the general rule prohibiting the admission of hearsay evidence.  Volkswagen of Am., Inc. v. Ramirez, 159 S.W.3d 897, 908 n. 5 (Tex. 2004).         


The business records exception provides that evidence meeting certain criteria should not be excluded under the hearsay rule.  See Tex. R. Evid. 803(6).  The exception has four requirements: (1) the records were made and kept in the course of a regularly conducted business activity; (2) it was the regular practice of the business activity to make the records; (3) the records were made at or near the time of the event that they record; and (4) the records were made by a person with knowledge who was acting in the regular course of business.  In re E.A.K., 192 S.W.3d 133, 141 (Tex. App._Houston [14th Dist.] 2006, pet. denied).  These requirements may be demonstrated at trial through an accompanying affidavit.  See Tex. R. Evid. 902(10). 

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