Randolph Brown v. Kula-Amos, Inc.

CourtCourt of Appeals of Texas
DecidedMarch 24, 2005
Docket02-04-00032-CV
StatusPublished

This text of Randolph Brown v. Kula-Amos, Inc. (Randolph Brown v. Kula-Amos, Inc.) 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
Randolph Brown v. Kula-Amos, Inc., (Tex. Ct. App. 2005).

Opinion

COURT OF APPEALS

SECOND DISTRICT OF TEXAS
FORT WORTH

 

NO. 2-04-032-CV

 
 

RANDOLPH BROWN                                                              APPELLANT

 

V.

 

KULA-AMOS, INC.                                                                    APPELLEE

 
 

------------

 

FROM COUNTY COURT AT LAW NO. 1 OF TARRANT COUNTY

   

MEMORANDUM OPINION1

   

I. Introduction

 

        Following a bench trial, the trial court entered judgment for Apellee Kula-Amos, Inc. (“Kula-Amos”) in its forcible detainer suit against Appellant Randolph Brown (“Brown”). The judgment awards Kula-Amos $3,126.39 in damages and possession of certain property that is the subject of a contract for deed between Kula-Amos and Brown. In five issues, Brown complains that the county court at law lacked jurisdiction over the suit, that Kula-Amos presented no evidence of ownership to demonstrate a superior right to immediate possession, that the notice of noncompliance provided to Brown failed to describe the period of the alleged deficiency, and that Kula-Amos did not allow Brown the statutorily prescribed amount of time to cure the default. We will affirm.

II. Factual and Procedural Background

        Brown and Kula-Amos entered into a contract for deed on September 4, 2000. Brown agreed to purchase and Kula-Amos agreed to sell the property located at 5607 Fireside Drive in Arlington. The contract for deed contains numerous standard terms as well as sections outlining Brown’s obligations, Kula-Amos’s rights, and other general provisions. The deed further provides that Kula-Amos will convey the property to Brown once Brown “has paid the entire Deferred Principal Amount, earned interest, and any other indebtedness owed under th[e] contract.” Kula-Amos sent Brown a notice of noncompliance with the terms of the contract on August 18, 2003. The notice indicated that Brown failed to make payments for the period from July 1, 2003 to July 31, 2003 and that Kula-Amos intended to enforce the remedy of forfeiture and acceleration if payment was not made by September 2, 2003. Brown responded to the letter and stated that he paid the amounts due under the contract for June and July 2003, but that he had not yet paid the balance due for August 2003. Brown further indicated that the amount due should be adjusted to reflect a new insurance policy that took effect August 1, 2003. Pete Still, the principal owner of Kula-Amos, acknowledged Brown’s letter and provided him with a breakdown of the monthly payment.

        Kula-Amos sent Brown a September 3, 2003 notice to vacate the premises. On September 12, 2003, Kula-Amos sued Brown and all occupants of the property located at 5607 Fireside Drive in justice court. The complaint provided that Brown failed to make a payment of $1359.26 due on August 1, 2003 and that on September 3, 2003 Kula-Amos had given Brown notice to vacate and demand for possession. Brown answered and submitted a plea to the jurisdiction, arguing that a “claim for unpaid rent or other damages is not part of an FED case” and that an “FED suit cannot be used to determine title to real property.” Attached to Brown’s answer was a contract for deed dated August 1, 2003 indicating that Brown agreed to sell and Mary Smith agreed to purchase the property located at 5607 Fireside Drive in Arlington. On October 2, 2003, the justice court entered a judgment for Kula-Amos, ordering that it recover possession of the property from Brown.

        Brown appealed the justice court judgment to the county court at law for a trial de novo. Once again, Brown answered and averred that the county court did not have jurisdiction to consider the case because an “FED suit cannot be used to determine title to real property.” After Jennifer Bowers, the vice president and property manager of Kula-Amos, and Brown testified, the county court requested that the parties provide it with a brief concerning the adequacy of the notice provided to Brown in the August 18, 2003 notice of noncompliance. The parties complied, and the county court subsequently signed a judgment on November 21, 2003 ordering that Kula-Amos have and recover possession of the property located at 5607 Fireside.  This appeal followed.2

III. County Court At Law Jurisdiction

        In his first issue, Brown argues that the county court did not have jurisdiction to consider Kula-Amos’s forcible detainer suit because the justice court did not initially have jurisdiction. Brown contends that the contract for deed executed by Brown and Mary Smith on August 1, 2003 caused the justice court to be “faced with a situation where there was an ownership interest in the property held by a person who was not a party to the proceeding.” This, Brown reasons, “required the determination of title.” Brown further maintains that Kula-Amos “could not appear in the Justice Court without an attorney” because “the filing of an eviction suit in the justice court is not a ministerial act, but rather, an act that was a nullity.”

        A. Jurisdiction

        Jurisdiction over a forcible detainer suit is given to a justice court in the precinct where the property is located.  See Tex. R. Civ. P. 749; Tex. Prop. Code Ann. § 24.004 (Vernon 2000); Aguilar v. Weber, 72 S.W.3d 729, 731 (Tex. App.—Waco 2002, no pet.).  Either party may then appeal the justice court’s judgment to the county court for a trial de novo.  Aguilar, 72 S.W.3d at 731; Cattin v. Highpoint Village Apartments, 26 S.W.3d 737, 739 (Tex. App.—Fort Worth 2000, pet. dism’d w.o.j.).  The appellate jurisdiction of a statutory county court is confined to the jurisdictional limits of the justice court, and the county court does not have appellate jurisdiction if the justice court did not initially have jurisdiction.  See Ward v. Malone, 115 S.W.3d 267, 269 (Tex. App—Corpus Christi 2003, pet. denied); Aguilar, 72 S.W.3d at 731.

        A forcible detainer action is the procedure by which the right to immediate possession of real property is determined.  See Cattin, 26 S.W.3d at 738-39.  It is a special proceeding governed by particular statutes and rules found in sections 24.001 to 24.011 of the Texas Property Code and Texas Rules of Civil Procedure 738 to 755.  See id.  Forcible detainer actions are intended to be a summary, speedy, and inexpensive remedy for resolving the question of who is entitled to immediate possession of real property.  See id.; see also Ward

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Randolph Brown v. Kula-Amos, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/randolph-brown-v-kula-amos-inc-texapp-2005.