Robert T. Brockman, Individually, and Rental Systems, Inc. v. Robert M. Tyson and Dana Tyson

CourtCourt of Appeals of Texas
DecidedOctober 27, 2005
Docket01-03-01335-CV
StatusPublished

This text of Robert T. Brockman, Individually, and Rental Systems, Inc. v. Robert M. Tyson and Dana Tyson (Robert T. Brockman, Individually, and Rental Systems, Inc. v. Robert M. Tyson and Dana Tyson) 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
Robert T. Brockman, Individually, and Rental Systems, Inc. v. Robert M. Tyson and Dana Tyson, (Tex. Ct. App. 2005).

Opinion



Opinion issued October 27, 2005





In The

Court of Appeals

For The

First District of Texas


NO. 01-03-01335-CV

 __________

ROBERT T. BROCKMAN, INDIVIDUALLY, AND RENTAL SYSTEMS, INC., Appellants

V.

ROBERT M. TYSON ET UX DANA TYSON, Appellees


On Appeal from the 152nd District Court

Harris County, Texas

Trial Court Cause No. 2000-64325


MEMORANDUM OPINION

          This is an appeal from a final judgment that confirms an arbitration award relating to the enforcement of a severance payment provision. Robert M. Tyson and Dana Tyson, appellees, sued Robert T. Brockman and Rental Systems, Inc., appellants, for fraud, breach of contract, and fraudulent concealment. The case was arbitrated, and the arbitration panel rendered an award for the Tysons. In two points of error, Brockman and Rental Systems contend that (1) the trial court erred in confirming the arbitration award because the arbitration panel committed a gross mistake by applying the law of novation and mutual mistake and (2) the trial court erred in confirming the award when the arbitration panel abused its discretion and exceeded its authority by ignoring the terms and procedures of the governing contract in determining the remedy. We affirm.

Background

          On April 15, 1991, Brockman and Robert and Dana Tyson entered into an agreement that created Rental Systems, Inc.—a business that rented personal computers, electronic equipment, and associated services. Tyson provided the concept for the business, and Brockman provided the capital and commercial expertise.

          The 1991 agreement provided that, in the event that Tyson was terminated, resigned, or died, he would receive a Business Appreciation Incentive of 20% of the “Gain in Value” of Rental Systems. Dana Tyson was also a signatory to this agreement. In 1993, Tyson and Brockman purportedly entered into an Executive Compensation Plan that extinguished the old contract and served as the new, controlling contract. The 1993 Plan provided that, in the event that Tyson was terminated, resigned, or died, he would be provided payment of a “Compensation Value” based on the net book value of the company. Dana Tyson was not a signatory to the 1993 Plan.

          On November 4, 1999, Tyson’s employment terminated. Alleging that his signature on the 1993 Plan was forged or otherwise obtained by fraud or deceit, Tyson requested that he be provided for under the 1991 agreement. Rental Systems disagreed, and Tyson filed suit to recover the Tysons’ severance payment under the 1991 contract, alleging fraud, breach of contract, and fraudulent concealment. Rental Systems filed a motion to compel arbitration that was granted. During the four-day arbitration proceeding, Brockman testified that the 1993 Plan was created because the 1991 contract was lost. The Tysons, however, testified that the 1991 contract was not lost, and they produced a copy of the contract during the proceeding.

          The Arbitration Panel held that the 1993 Plan was unenforceable and that the 1991 agreement controlled. The arbitration award provided as follows:

We, the undersigned having been designated in accordance with the arbitration agreement of the parties reflected in Section 9 of the Employment Agreement dated January 7, 1997, having been duly sworn, and having heard all of the proofs, allegations, arguments, and authorities of the parties in a hearing on the merits conducted in Houston, Texas, on September 15, 16, 17, and 18, 2003, hereby unanimously AWARD as follows:

1.This is a net Award that takes into account all claims, defenses, and matters in dispute in this proceeding as reflected in (1) Claimants’ First Amended Specification of Arbitration Claims dated August 15, 2003, and (2) Respondents’ Original Answer dated January 29, 2001, filed in this case and brought forward from the state District Court proceeding. The parties have jointly requested a reasoned Award.

2.A central issue in this case is whether the termination of Bobby Tyson’s employment with RentSys as of November 4, 1999, is governed by an Agreement dated April 15, 1991, and signed by Robert Brockman in his capacity as President of RentSys, Bobby Tyson, and Dana Tyson (“the 1991 Contract”); or, instead, whether such termination is governed by a Rental Systems, Inc. Executive Compensation Plan dated July 9, 1993, and signed by Robert Brockman in his capacity as President of RentSys and Bobby Tyson, but not Dana Tyson (“the 1993 Contract”). Claimants contend that the 1991 Contract controls since the 1993 Contract should be legally unenforceable on various grounds. Respondents, on the other hand, contend that the 1993 Contract was a novation which replaced and superseded the 1991 Contract, and therefore, that the 1993 provisions should control.

3.The Arbitrators agree with the Claimants that the 1993 Contract is unenforceable, and therefore, that the 1991 Contract is to be given force and effect in this case. Robert Brockman’s testimony explaining the reason for the creation of the 1993 Contract was that the parties had “jointly declared the [1991 Contract] to be lost.” A conflict of testimony exists on this disputed fact. Mr. Tyson testified that the 1991 Contract was not lost, and Dana Tyson’s testimony and the actual production of the original 1991 Contract at the arbitration hearing demonstrated that the 1991 Contract was not, in fact, lost as erroneously presumed. Thus, although Bobby Tyson signed the 1993 Contract, the parties de facto, if not de jure, essentially had operated as though a mutual mistake of material fact occurred which was tantamount to a failure of formation or consideration. Pursuant to the doctrine of mutual mistake, when parties to an agreement have contracted under a misconception or ignorance of a material fact, the agreement will be voided. Moreover, neither Bobby Tyson nor Robert Brockman intended for the 1993 Contract to be a material modification of the 1991 Contract. As Robert Brockman explained, the 1993 Contract was only intended to duplicate or reconstruct the 1991 Contract. It did not. Such intention was frustrated further by the absence of Dana Tyson as a contracting party in 1993, and by the 1993 Contract’s definition of proceeds, in the event of termination, as the net book value of RentSys. It is to be noted that Texas is a community property state and because the parties elected to have Dana Tyson’s joinder in the 1991 Contract they should have obtained her consent to or wavier of the 1993 Contract, which was not obtained. We believe this fact is also important.

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Robert T. Brockman, Individually, and Rental Systems, Inc. v. Robert M. Tyson and Dana Tyson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/robert-t-brockman-individually-and-rental-systems--texapp-2005.