Regal Finance Company, Ltd. and Regal Finance Company II, Ltd. v. Tex Star Motors, Inc.

Texas Supreme Court·Decided August 20, 2010·No. 08-0148·Published

Opinion

IN THE SUPREME COURT OF TEXAS

════════════

No. 08-0148

════════════

Regal Finance Company, Ltd. and Regal Finance Company II, Ltd., Petitioners,

v.

Tex Star Motors, Inc., Respondent

════════════════════════════════════════════════════

On Petition for Review from the

Court of Appeals for the Fourteenth District of Texas

════════════════════════════════════════════════════

Argued September 9, 2009

            Justice Johnson, dissenting.

            The Court concludes there is some evidence to support the jury’s findings of damages based on Regal’s disposal of repossessed vehicles in a commercially reasonable manner, even though there is no evidence the dispositions conformed to standards in the one jury instruction setting out how sales could be commercially reasonable. The Court’s holding effectively approves the jury’s having decided on its own what the standards are for commercially reasonable dispositions of repossessed automobiles. It then remands the case for the court of appeals to measure the factual sufficiency of the evidence against that unknown standard.

            The Court’s analysis is flawed in two major ways. First, the Court does not adhere to the rule that sufficiency of the evidence must be measured against definitions as they are given in the jury charge, even if the definitions are incomplete or incorrect. Second, lay jurors are not presumed to know the meaning of legal terms such as “commercially reasonable.” So even assuming it would have been proper for the jury to determine whether Regal’s sales of vehicles were commercially reasonable using a standard other than the definition given in the charge, the only way the jury would have known another standard would have been through evidence such as properly qualified expert testimony regarding the other standard. There was no such evidence. Accordingly, I disagree with the Court’s conclusion that there is legally sufficient evidence Regal’s sales were commercially reasonable and thus disagree with its holding that there is legally sufficient evidence of Regal’s damages to the extent those damages were based on commercially reasonable sales.

I. The Jury Charge Defined “Commercially Reasonable”

            The jury charge contained standard instructions, including the instruction that “[w]hen words are used in this charge in a sense that varies from the meaning commonly understood, you are given a proper legal definition, which you are bound to accept in place of any other meaning.” See Tex. R. Civ. P. 226a. A trial court must submit “such instructions and definitions as shall be proper to enable the jury to render a verdict.” Tex. R. Civ. P. 277. Jury charges are directed to lay jurors untrained in the law, thus charge language is evaluated from the perspective of such a juror. See Columbia Rio Grande Healthcare, L.P. v. Hawley, 284 S.W.3d 851, 862 (Tex. 2009); Galveston, H. & S.A. Ry. Co. v. Washington, 63 S.W. 534, 538 (Tex. 1901).

            Neither of the parties nor the Court maintains that laypersons have a common understanding of the legal term “commercially reasonable” as it is used in the Uniform Commercial Code (UCC). Thus, the term is one that should have been defined in the charge. See Tex. & P. Ry. Co. v. Mercer, 90 S.W.2d 557, 560 (Tex. 1936) (explaining that “proximate cause” is a legal phrase requiring definition); Magnolia Petroleum Co. v. Long, 86 S.W.2d 450, 455 (Tex. 1935); Reliable Consultants, Inc. v. Jaquez, 25 S.W.3d 336, 344 (Tex. App.—Austin 2000, pet. denied); Mayes v. Stewart, 11 S.W.3d 440, 455 (Tex. App.—Houston [1st Dist.] 2000, pet. denied) (“While the trial court must explain legal or technical terms, its discretion in determining the sufficiency of such explanations is broad.”); Johnson v. Whitehurst, 652 S.W.2d 441, 447 (Tex. App.—Houston [1st Dist.] 1983, writ ref’d n.r.e.) (“The only requirement to be observed is that the trial court must give definitions of legal and other technical terms.”).

            The issue arises from Question 6 of the charge which submitted Regal’s alleged damages. The question began by asking what sum of money, if any, would fairly and reasonably compensate Regal for its damages. The question had four parts with separate elements of damages submitted in each part. Parts (a) and (b) and their accompanying instructions are the parts relevant to the Court’s decision. In those parts, the jury was instructed to find Regal’s damages measured by

a. The difference, if any, between the unpaid balance on all Loans that Tex Star has not guaranteed and the amount received by [Regal] upon the sale of the vehicles that served as collateral for such Loans.

In answering this question, consider only Loans relating to vehicles that [Regal] sold in good faith and in a commercially reasonable manner. Good faith means honesty in fact and the observance of reasonable commercial standards of fair dealing.

Every aspect of the disposition, including the method, manner, time, place and other terms must be commercially reasonable. A sale is commercially reasonable if it conforms to reasonable commercial practices among dealers in the type of property that was the subject of the sale.

The fact that a greater amount could have been obtained by a collection, enforcement, disposition, or acceptance at a different time or in a different method from that selected by [Rega

Free access — add to your briefcase to read the full text and ask questions with AI

Regal Finance Company, Ltd. and Regal Finance Company II, Ltd. v. Tex Star Motors, Inc., (Tex. 2010).

Regal Finance Company, Ltd. and Regal Finance Company II, Ltd. v. Tex Star Motors, Inc. (Regal Finance Company, Ltd. and Regal Finance Company II, Ltd. v. Tex Star Motors, Inc.) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

FFE Transportation Services, Inc. v. Fulgham
154 S.W.3d 84 (Texas Supreme Court, 2004)
MacK Trucks, Inc. v. Tamez
206 S.W.3d 572 (Texas Supreme Court, 2006)
Columbia Rio Grande Healthcare, L.P. v. Hawley
284 S.W.3d 851 (Texas Supreme Court, 2009)
Romero v. KPH Consolidation, Inc.
166 S.W.3d 212 (Texas Supreme Court, 2005)
City of Fort Worth v. Zimlich
29 S.W.3d 62 (Texas Supreme Court, 2000)
Osterberg v. Peca
12 S.W.3d 31 (Texas Supreme Court, 2000)
Johnson v. Whitehurst
652 S.W.2d 441 (Court of Appeals of Texas, 1983)
Turbines, Inc. v. Dardis
1 S.W.3d 726 (Court of Appeals of Texas, 1999)
Mayes v. Stewart
11 S.W.3d 440 (Court of Appeals of Texas, 2000)
Reliable Consultants, Inc. v. Jaquez
25 S.W.3d 336 (Court of Appeals of Texas, 2000)
Texas & Pacific Railway Co. v. Mercer
90 S.W.2d 557 (Texas Supreme Court, 1936)
Magnolia Petroleum Co. v. Long
86 S.W.2d 450 (Texas Supreme Court, 1935)