Ryan Stancu v. Southern Methodist University

CourtCourt of Appeals of Texas
DecidedJuly 15, 2022
Docket05-21-00666-CV
StatusPublished

This text of Ryan Stancu v. Southern Methodist University (Ryan Stancu v. Southern Methodist University) 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
Ryan Stancu v. Southern Methodist University, (Tex. Ct. App. 2022).

Opinion

DISMISS and Opinion Filed July 15, 2022

S In The Court of Appeals Fifth District of Texas at Dallas No. 05-21-00666-CV

RYAN STANCU, Appellant V. SOUTHERN METHODIST UNIVERSITY, Appellee

On Appeal from the 101st Judicial District Court Dallas County, Texas Trial Court Cause No. DC-20-14134

MEMORANDUM OPINION Before Justices Schenck, Osborne, and Smith Opinion by Justice Schenck The trial court dismissed Ryan Stancu’s suit against Southern Methodist

University (“SMU”) with prejudice after sustaining SMU’s special exceptions to

Stancu’s original petition on the applicable statute of limitations. Stancu filed a pro

se appeal claiming he was entitled to an in-person hearing on SMU’s special

exceptions and that the trial court erred in dismissing his claims without giving him

an opportunity to amend his pleadings. We dismiss this appeal for lack of

jurisdiction. Because all issues are settled in law, we issue this memorandum

opinion. TEX. R. APP. P. 47.4. BACKGROUND1

Stancu attended SMU as an undergraduate. He graduated in 2016. During

the graduation ceremony on May 14, 2016, Stancu received a letter in his diploma

folder informing him that SMU was withholding his diploma because of an unpaid

account.2 The parties negotiated a payment plan, but ultimately could not agree on

its terms. SMU sent the account to a collection agency.

On September 28, 2020, Stancu filed suit against SMU asserting claims for

breach of contract, violations of the Texas Deceptive Trade Practices Act, and

retaliation.3 Each of Stancu’s claims was based on the damages he alleged he

suffered as a result of SMU requiring him to pay the outstanding balance on his

student account.

On November 23, 2020, SMU filed special exceptions to Stancu’s petition

claiming, in part, the petition demonstrates on its face that all of Stancu’s claims are

time-barred. See Kendall v. Poos, No. 05-99-01391-CV, 2001 WL 580136, at *3

(Tex. App.—Dallas May 31, 2001, no pet.) (not designated for publication)

(recognizing that when a pleading affirmatively alleges facts demonstrating suit is

1 The background facts set forth in this opinion are gleaned from Stancu’s petition, including his admission that he received notice on May 14, 2016, that SMU was withholding his diploma until he paid the balance owed on his student account. Horizon/CMS Healthcare Corp. v. Auld, 34 S.W.3d 887, 905 (Tex. 2000) (clear, deliberate, and unequivocal assertions of fact in live pleadings are regarded as judicial admissions, barring the party making the assertion from disputing it). 2 SMU advised Stancu that any potential employer may verify his degree and enrollment dates through the National Student Clearinghouse. 3 There is no common law claim for retaliation and no statutory claim for retaliation applicable to this case. –2– time barred, limitations may be raised by special exception); see also Allied

Chemical Corp. v. Koonce, 548 S.W.2d 80, 82 (Tex. App.—Houston [1st Dist.]

1977, no writ) (trial court did not err in sustaining special exceptions because the

petition showed on its face that it was barred by limitations). Consistent with the

Texas Supreme Court’s Twenty-Ninth Emergency Order Regarding COVID-19

State of Disaster and the Dallas County district courts’ emergency standing order in

place at the time, both of which allowed courts to require remote hearings, a hearing

on SMU’s special exceptions was set for January 26, 2021, to be held remotely “at

a link/or dial-in to be provided by the court.”

On December 18, 2020, Stancu filed an answer to SMU’s special exceptions

and a request that the trial court hold an in-person hearing. Stancu claimed he did

not have the technological/electronic resources for a remote hearing. Stancu did not

obtain a ruling on his request to appear in person.

The trial court held a remote hearing on SMU’s special exceptions as

scheduled, and, on February 2, 2021, signed an order (i) indicating it had considered

Stancu’s original petition, the special exceptions thereto, and Stancu’s response to

the special exceptions; (ii) sustaining SMU’s special exception on the applicable

statutes of limitations; and (iii) dismissing Stancu’s claims with prejudice.

On July 13, 2021, the trial court, in error, sent a notice that this case was set

for trial on June 14, 2022. SMU’s counsel confirmed with the trial court that the

case had in fact been dismissed in February 2021. On July 29, 2021, SMU’s counsel

–3– advised Stancu of this fact. On August 3, 2021, Stancu filed his “Appeal to this

Court’s Wrongful Dismissal of Plaintiff’s Original Petition” in the district court.

The district court filed that notice with this Court the following day.

DISCUSSION

I. Nature of the Appeal

As a general rule, an appeal may only be taken after a final judgment.

Lehmann v. Har–Con Corp., 39 S.W.3d 191, 195 (Tex. 2001). A judgment is final

for purposes of appeal if it disposes of all pending parties and claims in the record.

Id. The trial court’s order of February 2, 2021, disposed of all pending parties and

claims in this case. Thus, it was final for the purposes of appeal.

A notice of appeal must be filed within thirty days of the trial court’s ruling,

unless the deadline is extended by the timely filing of certain kinds of post-judgment

motions. TEX. R. APP. P. 26.2(a). On August 16, 2021, this Court advised the parties

that Stancu’s appeal was not presented within the deadline for a traditional appeal

and thus it would proceed as a restricted appeal.

II. Requirements of a Restricted Appeal

In order for a restricted appeal to succeed (1) it must be brought within six

months after the judgment was signed, (2) by a party to the underlying lawsuit, (3)

who did not participate in the hearing that resulted in the judgment complained of

and did not timely file any post-judgment motions or requests for findings of fact

and conclusions of law, and (4) the claimed error must be apparent on the face of the

–4– record. TEX. R. APP. P. 26.1(c); 30; Ins. Co. of State of Pa. v. Lejeune, 297 S.W.3d

254, 255 (Tex. 2009). These requirements are jurisdictional and will cut off a party’s

right to seek relief by way of a restricted appeal if they are not met. Lab. Corp. of

Am. v. Mid–Town Surgical Ctr., Inc., 16 S.W.3d 527, 528–29 (Tex. App.—Dallas

2000, no pet.).

III. Application of Law to Facts

A. Timeliness of the Notice of Appeal

As an initial matter, we note Stancu filed his notice of appeal six months and

one day after the trial court signed the order sustaining SMU’s special exceptions.

Rule of Appellate Procedure 30, which governs restricted appeals, requires that the

notice of appeal be filed within six months after the judgment was signed. See TEX.

R. APP. P. 26.1(c). Rule 26.3 permits an extension of time to file the notice of appeal

for fifteen days after the deadline. See TEX. R. APP. P. 26.3. Thus, Stancu had to

file the notice of appeal within six months and fifteen days after August 2, 2021. See

Lab.

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Baylor University v. Sonnichsen
221 S.W.3d 632 (Texas Supreme Court, 2007)
Insurance Co. of the State of Pennsylvania v. Lejeune
297 S.W.3d 254 (Texas Supreme Court, 2009)
Laboratory Corp. of America v. Mid-Town Surgical Center, Inc.
16 S.W.3d 527 (Court of Appeals of Texas, 2000)
Horizon/CMS Healthcare Corporation v. Auld
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Allied Chemical Corp. v. Koonce
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Ryan Stancu v. Southern Methodist University, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ryan-stancu-v-southern-methodist-university-texapp-2022.