Shyam A. Jha v. Bank of America, N.A.

CourtCourt of Appeals of Texas
DecidedApril 27, 2023
Docket02-22-00240-CV
StatusPublished

This text of Shyam A. Jha v. Bank of America, N.A. (Shyam A. Jha v. Bank of America, N.A.) 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
Shyam A. Jha v. Bank of America, N.A., (Tex. Ct. App. 2023).

Opinion

In the Court of Appeals Second Appellate District of Texas at Fort Worth ___________________________ No. 02-22-00240-CV ___________________________

SHYAM A. JHA, Appellant

V.

BANK OF AMERICA, N.A., Appellee

On Appeal from County Court at Law No. 2 Tarrant County, Texas Trial Court No. 2019-000608-2

Before Womack, Wallach, and Walker, JJ. Memorandum Opinion by Justice Wallach MEMORANDUM OPINION

Appellant Shyam A. Jha, appearing pro se, appeals from the trial court’s

judgment in favor of Appellee Bank of America, N.A. (BANA) in a suit for account

stated. We will affirm.

I. Background

In January 2019, BANA, a wholly-owned subsidiary of Bank of America

Corporation and the successor-in-interest to FIA Card Services, N.A. (FIA) f/k/a

MBNA America, N.A., sued Jha to recover a credit card debt in the amount of

$2,976.96.1

In October 2020, the trial court held a bench trial. At the start of the trial,

BANA offered Jha’s credit card account statements—totaling ninety-six pages—into

evidence under the business records exception to the hearsay rule. See Tex. R. Evid.

803(6), 902(10). Jha objected to the credit card account statements’ admission on the

grounds that the business record affidavit accompanying the statements did not satisfy

the requirements of Rule 902(10) and that the records were not “complete.” The trial

court overruled Jha’s objection and admitted the credit card account statements into

evidence.

BANA then called Jha as a witness. Under examination from BANA’s counsel,

Jha admitted that he currently resided at the address reflected on the credit card

1 The specific cause of action asserted in BANA’s petition is “account stated.”

2 account statements and had lived there for approximately eighteen years; that he had

an account with BANA ending in 3706 as reflected on the statements; that he had

used the account to make purchases; that he had made payments on the account; that

he had ceased making payments on the account; and that there was a remaining

balance due and owing on the account.

Jha argued that because he had originally opened his credit card account with

MBNA America—BANA’s predecessor-in-interest2—and because BANA had neither

proven what rights it had as “assignee” nor had offered the original agreement

between Jha and MBNA America into evidence, BANA had not proven all the

elements of its account-stated cause of action. Jha also argued that the amount of the

debt was incorrect because it had been calculated based on amended credit terms to

which Jha had not agreed.3 However, on cross-examination, Jha admitted that he had

never objected to any of the amendments to the credit agreement and had continued

to use his credit card after each amendment.

In March 2022, the trial court signed a judgment awarding BANA

$2,600.10 and court costs. Upon Jha’s request, the trial court issued findings of fact

and conclusions of law in May 2022. This appeal followed.

2 Jha opened his credit card account in 2003. MBNA America changed its name to FIA in 2006. FIA “merged into and under the charter and title of” BANA in 2014. 3 When asked what he believed to be the correct debt amount, Jha testified that he had “not calculated that.”

3 II. Discussion

Jha raises two issues on appeal. First, he asserts that the trial court abused its

discretion by admitting his credit card account statements into evidence as business

records. Second, he argues that the evidence is factually insufficient to support the

trial court’s judgment. These arguments lack merit.

A. Admission of the Credit Card Account Statements

In his first issue, Jha argues that the trial court erred by admitting his credit card

account statements into evidence as business records. Specifically, Jha contends that

the business records affidavit accompanying the statements did not satisfy the

requirements of Rules 803(6) and 902(10) and that he had “demonstrate[d] that the

source of information or the method or circumstances of preparation indicate[d] a

lack of trustworthiness.” See Tex. R. Evid. 803(6)(E), 902(10).

We will not disturb a trial court’s evidentiary rulings absent an abuse of

discretion. See Fleming v. Wilson, 610 S.W.3d 18, 21 (Tex. 2020); Bay Area Healthcare

Grp. Ltd. v. McShane, 239 S.W.3d 231, 234 (Tex. 2007). “A trial court abuses [its]

discretion when it acts without regard for guiding rules or principles.” U-Haul Int’l, Inc.

v. Waldrip, 380 S.W.3d 118, 132 (Tex. 2012). But even if a trial court’s evidentiary

ruling constitutes an abuse of discretion, reversal is appropriate only if the error was

harmful. Id.; Tex. R. App. P. 44.1.

Hearsay is not admissible unless a statute or the rules of evidence provide

otherwise. Tex. R. Evid. 802. Pursuant to Rule 803(6)—commonly referred to as the

4 business records exception—records of a regularly conducted activity are admissible

provided that the requirements of the rule are met.4 Tex. R. Evid. 803(6). Moreover,

business records accompanied by an affidavit meeting the requirements of Rule

902(10) are self-authenticating. Tex. R. Evid. 902(10).

Here, the business records affidavit attached to Jha’s credit card account

statements satisfied the requirements of Rules 803(6) and 902(10). The affiant Latasha

York averred that she is “a custodian of records of BANA and [is] familiar with the

manner in which its records are created and maintained by virtue of [her] duties and

responsibilities.” See Tex. R. Evid. 803(6)(D), 902(10)(B). York specified that

4 Rule 803(6) provides that “[a] record of an act, event, condition, opinion, or diagnosis” is not excluded by the rule against hearsay if

(A) the record was made at or near the time by—or from information transmitted by—someone with knowledge;

(B) the record was kept in the course of a regularly conducted business activity;

(C) making the record was a regular practice of that activity;

(D) all these conditions are shown by the testimony of the custodian or another qualified witness, or by an affidavit or unsworn declaration that complies with Rule 902(10); and

(E) the opponent fails to demonstrate that the source of information or the method or circumstances of preparation indicate a lack of trustworthiness. “Business” as used in this paragraph includes every kind of regular organized activity whether conducted for profit or not.

Tex. R. Evid. 803(6).

5 “96 pages of records” were attached to her affidavit and confirmed that they were

“the original records or exact duplicates of the original records . . . .” See Tex. R. Evid.

902(10)(B). She further averred that “[t]he records were made at or near the time of

each act or event they purport to describe occurred”; that they “were kept in the

course of [a] regularly conducted business activity”; and that “[i]t is the regular

practice of the business activity to make the records.” See Tex. R. Evid. 803(6)(A)–(C),

902(10)(B).

Although Jha attempted “to demonstrate that the source of information or the

method or circumstances of preparation” of the credit card account statements

“indicate a lack of trustworthiness,” we cannot conclude that the trial court erred by

implicitly finding that he failed to do so.

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