Phillip Chen and Jiang Chen v. DFW Home Services, LLC D/B/A DFW

Texas Court of Appeals, 2nd District (Fort Worth)·Decided April 30, 2026·No. 02-25-00620-CV·Published

Opinion

In the

Court of Appeals

Second Appellate District of Texas at Fort Worth

No. 02-25-00620-CV

PHILLIP CHEN AND JIANG CHEN, Appellants V.

DFW HOME SERVICES, LLC D/B/A DFW IMPROVED, Appellee

On Appeal from the 67th District Court Tarrant County, Texas

Trial Court No. 067-349646-24

Before Birdwell, Wallach, and Walker, JJ.

Memorandum Opinion by Justice Walker

MEMORANDUM OPINION

I. INTRODUCTION

Following an arbitrator’s final award in favor of Appellee DFW Home Services, LLC d/b/a/ DFW Improved, Appellee moved to confirm the award, and Appellants Philip and Jiang Chen moved to vacate the award. The trial court granted Appellee’s motion and denied Appellants’ motion.

Appellants raise five appellate issues challenging the trial court’s order denying their motion to vacate. Because they fail to present a sufficient record of the arbitral proceeding to support their vacatur grounds and because they attempt to collaterally attack the award with complaints that were not presented to the arbitrator, we will affirm.

II. FACTUAL AND PROCEDURAL BACKGROUND In June and August of 2022, Appellants entered into two contracts with Appellee for restoration work on their home.1 Appellee completed the restoration work, but Appellants failed to fully make payment. Appellee recorded and perfected an affidavit claiming a lien on Appellants’ property and sent them a written demand for all amounts due and owing under the contracts. Appellants still did not make payment.

1 Both contracts contained an arbitration provision and a venue clause designating Collin County.

In January 2024, Appellee sued Appellants in Tarrant County,2 and they answered with a general denial. Pursuant to the contracts’ arbitration provisions, Appellee moved unopposed to compel arbitration, and the trial court granted an agreed order compelling arbitration and staying the action.

Following a one-day hearing,3 the arbitrator found, among other things, that Appellee was entitled to (1) contractual damages for its unpaid work, (2) foreclosure of its lien, and (3) reasonable and necessary attorney’s fees. The arbitrator signed the final award, and Appellee moved to confirm the award. Appellants responded that they did “not object to the entry of judgment.”

But before the trial court ruled on Appellee’s motion to confirm, Appellants moved to vacate the award, alleging that their rights had been prejudiced by the arbitrator’s evident partiality and that the arbitrator had refused to postpone the arbitration hearing after they showed sufficient cause for the postponement, refused to hear evidence material to the controversy, or conducted the hearing contrary to Texas Civil Practice and Remedies Code Sections 171.043–171.047. The motion did not provide further explanation or include any evidence in support of these

2 Appellee brought claims for breach of contract, quantum meruit, violation of the Texas Prompt Payment to Contractors and Subcontractors Act, foreclosure of lien, and attorney’s fees and costs.

3 There is no transcript of the arbitration hearing.

allegations. The trial court denied Appellants’ motion to vacate and granted Appellee’s motion to confirm.

Appellants then moved for a new trial, and alternatively, moved to modify, correct, reform, or reconsider the judgment—reasserting the same allegations from their motion to vacate.4 Appellee responded and argued that Appellants’ motion was essentially another motion to vacate because it was a regurgitation of the same previously asserted grounds and that they could not file another motion to vacate because the award had already been confirmed. A hearing was conducted on Appellants’ motion for new trial, but no evidence or new arguments were presented. The trial court denied the motion for new trial, and Appellants filed this appeal.

III. STANDARD OF REVIEW

An arbitration award is conclusive on the parties as to all matters of fact and law submitted to the arbitrator and has the effect of a judgment of a court of last resort. See CVN Grp., Inc. v. Delgado, 95 S.W.3d 234, 238 (Tex. 2002). Accordingly, judicial review of an arbitration award is extraordinarily narrow, and we may vacate an arbitration award only in very unusual circumstances. See Oxford Health Plans LLC v. Sutter, 569 U.S. 564, 568, 133 S. Ct. 2064, 2068 (2013); Rain CII Carbon, LLC v.

4 Appellants attached an affidavit from Appellant Philip Chen claiming—for the first time—that the arbitrator had stated during the arbitration hearing, “This is a fast[-]track arbitration, I do not get paid enough for this[,] and I do not have the time to review your evidence.” No transcript of the arbitration hearing was attached to support this claim.

ConocoPhillips Co., 674 F.3d 469, 472 (5th Cir. 2012); E. Tex. Salt Water Disposal Co. v. Werline, 307 S.W.3d 267, 271 (Tex. 2010).

To protect the strong deference accorded to arbitration awards, we review a trial court’s ruling to vacate or confirm an arbitration award de novo based on the entire record. See Denbury Onshore, LLC v. Texcal Energy S. Tex., L.P., 513 S.W.3d 511, 515 (Tex. App.—Houston [14th Dist.] 2016, no pet.); Royce Homes, L.P. v. Bates, 315 S.W.3d 77, 85 (Tex. App.—Houston [1st Dist.] 2010, no pet.). All reasonable presumptions are indulged in favor of the award, and the challenging party bears the burden to establish an allowable ground for vacatur. See Denbury Onshore, 513 S.W.3d at 515; Amoco D.T. Co. v. Occidental Petroleum Corp., 343 S.W.3d 837, 841 (Tex. App.— Houston [14th Dist.] 2011, pet. denied). We must focus on the integrity of the process—not the propriety of the result. See Ancor Holdings, LLC v. Peterson, Goldman & Villani, Inc., 294 S.W.3d 818, 826 (Tex. App.—Dallas 2009, no pet.).

Additionally, the Texas Supreme Court has stated the requirements for the arbitration record and for demonstrating error in an arbitration award:

A court must have a sufficient record of the arbitral proceedings, and complaints must have been preserved, all as if the award were a court judgment on appeal. For efficiency’s sake, arbitration proceedings are often informal; procedural rules are relaxed, rules of evidence are not followed, and no record is made. These aspects of arbitration, which are key to reducing costs and delay in resolving disputes, must fall casualty to the requirements for full judicial review. The parties can decide for themselves whether the benefits are worth the additional cost and delay, but the only review to which they can agree is the kind of review courts conduct. If error cannot be demonstrated, an award must be presumed correct.

Nafta Traders, Inc. v. Quinn, 339 S.W.3d 84, 101–02 (Tex. 2011) (footnotes omitted).

IV. DISCUSSION

In five issues—four of which are raised for the first time on appeal—

Appellants challenge the trial court’s denial of their motion to vacate. For ease of discussion, we will address Appellants’ issues out of order.

A. APPELLANTS’ GROUNDS FOR VACATUR In their fourth issue, Appellants allege that “[t]he Arbitrator’s actions necessitate vacating the award as the arbitrator demonstrated partiality [and] misconduct,[5] and refused to hear evidence material to the controversy.”

1. Applicable Law

By default, “[u]nless grounds are offered for vacating, modifying, or correcting an [arbitration] award,” the trial court “shall confirm the award.” Tex. Civ. Prac. & Rem. Code Ann. § 171.087. The available grounds for vacating, modifying, or correcting an arbitration award are statutorily delineated in the Texas Arbitration Act

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Phillip Chen and Jiang Chen v. DFW Home Services, LLC D/B/A DFW, (Tex. Ct. App. 2026).

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