Richard Vaughan v. Hartman Management

CourtCourt of Appeals of Texas
DecidedDecember 28, 2010
Docket14-09-00590-CV
StatusPublished

This text of Richard Vaughan v. Hartman Management (Richard Vaughan v. Hartman Management) 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
Richard Vaughan v. Hartman Management, (Tex. Ct. App. 2010).

Opinion

Affirmed and Memorandum Opinion filed December 28, 2010.

In The

Fourteenth Court of Appeals

NO. 14-09-00590-CV

RICHARD VAUGHAN, Appellant

V.

HARTMAN MANAGEMENT, Appellee

On Appeal from the 333rd District Court

Harris County, Texas

Trial Court Cause No. 2005-78080

MEMORANDUM OPINION

Appellant, Richard Vaughan, contends the trial court erred by rendering a take-nothing judgment on his breach-of-contract claim against Hartman Management Inc. based on the jury’s finding that Vaughan materially breached the contract.  Because the dispositive issues are clearly settled in law, we issue this memorandum opinion.  See Tex. R. App. P. 47.4.  The trial court’s judgment is affirmed.

I.   Background

In October 2002, Vaughan signed an employment agreement with Hartman Management Inc. (“Hartman Management”).[1]  Hartman Management was engaged in the business of soliciting investors for various real estate deals.  Vaughan was hired to serve as director of investor services.  During Vaughan’s employment, Allen Hartman (“Mr. Hartman”) was the president of Hartman Management.  Under the employment agreement, Vaughan was eligible to receive a “back-end participation” bonus based upon his performance. 

Vaughan resigned from Hartman Management in July 2005.  He later sued Hartman Management, asserting several claims for unpaid compensation, including amounts allegedly due as “back-end participation.”  Hartman Management responded by alleging that Vaughan materially breached the employment agreement and by asserting various counterclaims, including for defamation.  Mr. Hartman, in his individual capacity, intervened and asserted a defamation claim.  The trial court granted summary judgment in favor of Hartman Management relative to all of Vaughan’s breach-of-contract claims except for back-end participation.  However, in February 2008, the trial court abated the back-end participation claim, concluding that it was not ripe.

Vaughan’s claim for back-end participation ripened in October 2008 and was subsequently reinstated by the trial court.  Mr. Hartman’s defamation claim and Hartman Management’s material-breach defense were submitted to the jury.  The jury found against Mr. Hartman on his defamation claim.  The jury also found that Vaughan failed to comply with a material obligation of the employment agreement, thus excusing Hartman Management’s failure to pay Vaughan.  Vaughan filed a motion for judgment notwithstanding the verdict, arguing that there was no evidence supporting the finding that he materially breached the employment agreement.  The trial court denied Vaughan’s motion and rendered judgment on the jury’s findings, thereby ordering that Vaughan take nothing.

II.   Material Breach

In his first, second, and fourth issues, Vaughan contends the trial court erred by denying his motion for judgment notwithstanding the verdict, failing to determine as a matter of law that there was no material breach, and submitting a jury question regarding material breach when there was no evidence to support the submission.  The basis for all these issues is Vaughan’s contention there is no evidence supporting a finding that he failed to comply with a material obligation in the employment agreement.

A.   Standard of Review and Applicable Law

Judgment without or against a jury verdict is proper at any course of the proceedings only when the law does not allow reasonable jurors to decide otherwise.  City of Keller v. Wilson, 168 S.W.3d 802, 823 (Tex. 2005).  Accordingly, the test for legal sufficiency is the same for summary judgments, directed verdicts, judgments notwithstanding the verdict, and appellate no-evidence review.  Id.  

A legal-sufficiency point must be sustained when (1) there is a complete absence of a vital fact, (2) rules of law or evidence preclude according weight to the only evidence offered to prove a vital fact, (3) the evidence offered to prove a vital fact is no more than a scintilla, or (4) the evidence conclusively establishes the opposite of the vital fact.  Id. at 810.  Under the legal-sufficiency standard, we must credit evidence that supports the judgment if reasonable jurors could, and we must disregard contrary evidence unless reasonable jurors could not.  See id. at 827.  If the evidence falls within the zone of reasonable disagreement, we may not invade the fact-finding role of the jurors, who alone determine the credibility of witnesses, the weight to give their testimony, and whether to accept or reject all or any part of that testimony.  See id. at 822.  We must determine whether the evidence at trial would enable reasonable and fair-minded persons to find the facts at issue.  See id. at 827. 

A party breaches a contract by neglecting or refusing to perform an obligation prescribed in the contract.  Mays v. Pierce, 203 S.W.3d 564, 575 (Tex. App.—Houston [14th Dist.] 2006, pet. denied).  If the breach is material, the non-breaching party is excused from further performance of the contract if that party elects to treat the breach as material.[2]  See Hanks v. GAB Bus. Servs., Inc., 644 S.W.2d 707, 708 (Tex. 1982) (holding that nonbreaching party must timely decide whether to treat the breach of contract as a material breach or to treat the contract as still in effect); Kirby Lake Dev. v. Clear Lake City Water Auth., 321 S.W.3d 1, 7–8 (Tex. App.—Houston [14th Dist.] 2008) (same), aff’d, 320 S.W.3d 829, 843–44 (Tex. 2010).    

The following material-breach question was submitted to the jury: “Did Richard Vaughan fail to comply with a material obligation of his employment agreement with Hartman Management?”  The Texas Supreme Court has recognized certain non-exclusive factors that may be considered by a jury when determining the materiality of a breach.  See Mustang Pipeline Co., Inc. v. Driver Pipeline Co., Inc.

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Related

Mustang Pipeline Co. v. Driver Pipeline Co.
134 S.W.3d 195 (Texas Supreme Court, 2004)
Kirby Lake Development, Ltd. v. Clear Lake City Water Authority
320 S.W.3d 829 (Texas Supreme Court, 2010)
Osterberg v. Peca
12 S.W.3d 31 (Texas Supreme Court, 2000)
Mays v. Pierce
203 S.W.3d 564 (Court of Appeals of Texas, 2006)
Kroger Co. v. Brown
267 S.W.3d 320 (Court of Appeals of Texas, 2008)
City of Keller v. Wilson
168 S.W.3d 802 (Texas Supreme Court, 2005)
Kirby Lake Development, Ltd. v. Clear Lake City Water Authority
321 S.W.3d 1 (Court of Appeals of Texas, 2008)
Hanks v. GAB Business Services, Inc.
644 S.W.2d 707 (Texas Supreme Court, 1982)

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Richard Vaughan v. Hartman Management, Counsel Stack Legal Research, https://law.counselstack.com/opinion/richard-vaughan-v-hartman-management-texapp-2010.