Quadvest, L.P. and Woodland Oaks Utility, L.P. v. San Jacinto River Authority

CourtCourt of Appeals of Texas
DecidedMay 9, 2024
Docket09-23-00167-CV
StatusPublished

This text of Quadvest, L.P. and Woodland Oaks Utility, L.P. v. San Jacinto River Authority (Quadvest, L.P. and Woodland Oaks Utility, L.P. v. San Jacinto River Authority) 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
Quadvest, L.P. and Woodland Oaks Utility, L.P. v. San Jacinto River Authority, (Tex. Ct. App. 2024).

Opinion

In The

Court of Appeals

Ninth District of Texas at Beaumont

__________________

NO. 09-23-00167-CV __________________

QUADVEST, L.P. AND WOODLAND OAKS UTILITY, L.P., Appellants

V.

SAN JACINTO RIVER AUTHORITY, Appellee

__________________________________________________________________

On Appeal from the 284th District Court Montgomery County, Texas Trial Cause No. 20-08-10189-CV __________________________________________________________________

MEMORANDUM OPINION

In a permissive interlocutory appeal, Quadvest, L.P. and Woodland

Oaks Utility, L.P. (collectively, the Utilities) seek to reverse the trial

court’s ruling granting the San Jacinto River Authority’s Motion for

Partial Traditional Summary Judgment. In its ruling, the trial court

determined that the Utilities did not have the right to assert certain

affirmative defenses to the SJRA’s breach of contract claim for payment 1 under the decades-long contracts the parties executed in 2010, which the

SJRA used to secure the repayment of its debt in return for the sale of

seven series of outstanding bonds. In granting the SJRA’s motion, the

trial court concluded that, under the statutes that applied to the SJRA’s

bonds, the legislature made the validity of a local governmental entity’s

contracts pledged to secure a debt obligation and approved through the

process required by these statutes “incontestable in a court or other

forum.” 1

The Utilities appeal from that ruling and, in their brief, they raise

two appellate issues for our review. First, the Utilities argue that when

it passed the statutes applicable to the SJRA’s contracts and bonds, the

legislature did not intend to strip entities that execute contracts with

local governmental entities of their right to raise defenses that challenge

the validity or the enforceability of the contracts on which a local

governmental entity’s claims are based. Second, the Utilities argue that

by interpreting the statutes that apply to the SJRA’s bonds in a manner

that prevents them from defending against the SJRA’s breach of contract

1Tex. Gov’t Code Ann. §§ 1202(a); 1371.059(a) (Supp); Texas Water

Code Ann. § 49.184(b). 2 claim on the ground that their contracts with the Utilities should be set

aside as unenforceable or void, the trial court gave the statutes an

interpretation that violates their constitutional rights under the

separation of powers doctrine, the open courts provision, the due course

of law clause under the Texas Constitution, and the right to Due Process

under the United States Constitution. 2

The summary-judgment evidence established that the SJRA’s

contracts with the Utilities were submitted and approved by the Texas

Attorney General and registered with the Comptroller’s Office. That is

the process the legislature created to make contracts pledged by local

governmental entities incontestable according to their terms for contracts

that local governmental entities have pledged to secure the payment of

the debt on their bonds. Furthermore, the terms of the parties’ contracts

do not make the validity of the contracts contestable based on the

affirmative defenses that the Utilities raised to the SJRA’s claim for

payment that are the subject of the SJRA motion for summary judgment.

Rather, in the contracts the parties executed, they included specific

2Tex. Const. art. I, § 13 (Open Courts); Tex. Const. art. I, § 19 (Due

Course of Law); U.S. CONST. amend. XIV, § 1 (Due Process). 3 provisions setting out the remedies that were to be available to a party

should a party default on its obligations under its contract. Those

provisions don’t include a provision in which the Utilities reserved a right

to assert a claim that the contracts are either unenforceable or void.

The legislature made contracts pledged by local governmental units

“incontestable” once they were approved in the required statutory

authorization process, a process that no one disputes occurred here. The

terms of the contracts the Utilities signed also include no provisions

expressly reserving to the Utilities any right to assert a defense on the

theory that the contracts are unenforceable or void. For those reasons as

further explained below, we conclude the trial court did not err in

granting the SJRA’s motion.

Background

Simply put, this dispute is largely about the legislature’s intended

meaning of the term incontestable in the three statutes that the parties

point to in their brief, which all parties agree apply to the Utilities’ bonds

and their contracts. 3 In these statutes, the legislature didn’t specifically

3Tex. Gov’t Code Ann. § 1202.006 (Validity and Incontestability), §

137.059 (Validity and Incontestability); Tex. Water Code Ann. § 49.184(c) 4 define the meaning of the word incontestable. 4 Once we decide what that

term means, we must look to the terms of the contracts to determine

whether the defenses on which the trial court granted the SJRA’s motion

were reserved or waived.

For the purposes of this appeal, we will call the three statutes that

apply to the Utilities’ bonds and contracts the bond-approval statutes.5

In the trial court and on appeal, the Utilities argue that the bond-

approval statutes make the bonds incontestable by a local governmental

entity, but the statutes do not make the contracts pledged by the local

governmental entity to back its repayment of its debt on the bonds

incontestable as against those that signed the contracts that represent

the security for the SJRA’s repayment of its debt.

The Utilities are privately-owned companies that provide water to

customers in Montgomery County by selling them groundwater, which

they pump from the Gulf Coast Aquifer for a profit. 6 That said, the

Utilities are just two of the many large-volume groundwater users that

(providing that a contract pledged to the payment of a bond once submitted and approved by the attorney general “shall be incontestable”). 4Id. 5Id. 6See Tex. Water Code Ann. § 36.002.

5 have historically relied on groundwater in Montgomery County for the

water they supply to their customers. As the population in Montgomery

County has grown, so have concerns about the extent to which large-

volume groundwater users have relied on groundwater drawn from the

Gulf Coast Aquifer for their supplies. In 2001, the legislature created the

Lone Star Groundwater Conservation District (the Conservation

District) to address that concern. 7 Under the Texas Water Code, the

legislature gave water conservation districts the power to “make and

enforce rules . . . to provide for conserving, preserving, protecting, and

recharging of the groundwater or of a groundwater reservoir . . . in order

to control subsidence, prevent degradation of water quality, or prevent

waste of groundwater and to carry out the powers and duties provided by

this chapter[,]” Texas Water Code Chapter 36. 8

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Quadvest, L.P. and Woodland Oaks Utility, L.P. v. San Jacinto River Authority, Counsel Stack Legal Research, https://law.counselstack.com/opinion/quadvest-lp-and-woodland-oaks-utility-lp-v-san-jacinto-river-texapp-2024.