Playnation Play Systems, Inc. v. Felix Guajardo D/B/A Guajardo Turf Farms

CourtCourt of Appeals of Texas
DecidedMay 17, 2007
Docket13-06-00302-CV
StatusPublished

This text of Playnation Play Systems, Inc. v. Felix Guajardo D/B/A Guajardo Turf Farms (Playnation Play Systems, Inc. v. Felix Guajardo D/B/A Guajardo Turf Farms) 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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Playnation Play Systems, Inc. v. Felix Guajardo D/B/A Guajardo Turf Farms, (Tex. Ct. App. 2007).

Opinion





NUMBER 13-06-302-CV



COURT OF APPEALS



THIRTEENTH DISTRICT OF TEXAS



CORPUS CHRISTI - EDINBURG

PLAYNATION PLAY SYSTEMS, INC. Appellant,



v.



FELIX GUAJARDO D/B/A GUAJARDO TURF FARMS, Appellee.

On appeal from the County Court at Law No. 5 of

Hidalgo County, Texas.

MEMORANDUM OPINION



Before Justices Yañez, Benavides, and Vela

Memorandum Opinion by Justice Benavides



In this appeal we must decide whether appellee Felix Guajardo, a resident of Hidalgo County, Texas, may collaterally attack a judgment issued against him by a court in Cobb County, Georgia for lack of jurisdiction. We find that the Georgia court gave Guajardo an adequate opportunity to fully and fairly litigate the issue of jurisdiction. Thus, the Texas court where appellant PlayNation Play Systems, Inc. sought to domesticate the judgment is obligated by the Full Faith and Credit Clause of the United States Constitution to recognize the validity of the Georgia court ruling. We hold that the Texas trial court's failure to recognize the Georgia judgment was an abuse of discretion. Therefore, we reverse the trial court's judgment and remand for enforcement proceedings.

I. Background

PlayNation Play Systems, Inc. ("PlayNation") manufactures playground equipment for children. The firm's corporate headquarters and manufacturing facility is located in Georgia, but PlayNation sells its products through a network of authorized retailers positioned throughout the United States. Felix Guajardo was one such retailer. He sold PlayNation's equipment through his sole proprietorship, Guajardo Turf Farms, in Hidalgo County, Texas.

Guajardo claims to have become dissatisfied with the equipment that he ordered from PlayNation because, contrary to the assurances given to him by PlayNation, the equipment bent and warped in the hot climate of South Texas, leaving him with damaged products that he could not sell. Guajardo refused to pay PlayNation for the allegedly defective playground equipment. PlayNation, in turn, terminated its relationship with Guajardo and sued him for breach of contract in Cobb County, Georgia.

Through counsel, Guajardo voluntarily entered a limited appearance and motion to dismiss for lack of jurisdiction and venue in the Georgia court. The court found that Guajardo had the requisite minimum contacts with Georgia to justify in personam jurisdiction. Guajardo never appealed the ruling, nor appeared for his subsequent trial. (1) On August 25, 2003, the court rendered a default judgment against him for $57,094.00. Guajardo did not appeal the default judgment.

PlayNation then attempted to domesticate the Georgia judgment in County Court at Law No. 5 in Hidalgo County, Texas, but the Texas trial court found that the Georgia court lacked in personam jurisdiction over Guajardo and declared the judgment "null and void." PlayNation now appeals.

II. Standard of Review

A contest to the enforcement of a foreign judgment operates essentially as a motion for new trial and is thus reviewed under an abuse of discretion standard. Mindis Metals, Inc. v. Oilfield Motor & Control, Inc., 132 S.W.3d 477, 483 (Tex. App.-Houston [1st Dist.] 2004, pet. denied). The test for abuse of discretion is whether the trial court acted without reference to any guiding rules or principles, or whether under the circumstances of the case, the trial court's actions were arbitrary or unreasonable. Downer v. Aquamarine Operators, Inc., 701 S.W.2d 238, 241-42 (Tex. 1985).

A collateral attack may be asserted in order to set aside judgments that are void for lack of personal jurisdiction. Zarate v. Sun Oper. Ltd., Inc., 40 S.W.3d 617, 620 (Tex. App.-San Antonio 2001, pet. denied); see also Bland Indep. Sch. Dist. v. Blue, 34 S.W.3d 547, 554 (Tex. 2000) (stating that "the purpose of a plea to the jurisdiction is to defeat a cause of action without regard to whether the claims asserted have merit"). When reviewing collateral attacks, public policy strongly favors recognizing the validity of judgments; therefore, we must indulge all presumptions consonant with reason in order to uphold the binding effect of such judgments. Charles Brown, L.L.P. v. Lanier Worldwide, Inc., 124 S.W.3d 883, 894 (Tex. App.-Houston [14th Dist.] 2004, no pet.); Johnson v. Ventling, 132 S.W.3d 173, 177 (Tex. App.-Corpus Christi 2004, no pet.). The judgment debtor bears the burden of overcoming the full faith and credit given to foreign judgments. Cash Register Sales & Servs. of Houston v. Copelco Capital, 62 S.W.3d 278, 280-81 (Tex. App.-Houston [1st Dist.] 2001, no pet.). The presumption can only be overcome by establishing one of the following exceptions by clear and convincing evidence: (1) that a decree is interlocutory; (2) that a decree is subject to modification under the law of the rendering state; (3) that the judgment was procured by extrinsic fraud; (4) that the period for enforcing the judgment has expired; or (5) that the rendering court lacks jurisdiction. Mindis Metals, 132 S.W.3d at 484-85; see also Brown's, Inc. v. Modern Welding Co., 54 S.W.3d 450, 454 (Tex. App.-Corpus Christi 2001, no pet.). A judgment debtor can meet the burden of demonstrating a court's lack of jurisdiction by demonstrating, for example, that a sister-state's exercise of in personam jurisdiction offends due process of law. Cash Register Sales, 62 S.W.3d at 281; Markham v. Diversified Land & Exploration Co., 973 S.W.2d 437, 439 (Tex. App.-Austin 1998, pet. denied).

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Playnation Play Systems, Inc. v. Felix Guajardo D/B/A Guajardo Turf Farms, Counsel Stack Legal Research, https://law.counselstack.com/opinion/playnation-play-systems-inc-v-felix-guajardo-dba-g-texapp-2007.