STL Dealer Group, LTD v. Americredit Financial Services, Inc.

CourtCourt of Appeals of Texas
DecidedFebruary 17, 2011
Docket01-09-00613-CV
StatusPublished

This text of STL Dealer Group, LTD v. Americredit Financial Services, Inc. (STL Dealer Group, LTD v. Americredit Financial Services, Inc.) 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
STL Dealer Group, LTD v. Americredit Financial Services, Inc., (Tex. Ct. App. 2011).

Opinion

Opinion issued February 17, 2011

In The

Court of Appeals

For The

First District of Texas

————————————

NO. 01-09-00613-CV

———————————

SLT Dealer Group, Ltd. dba Alliance Chevrolet, Appellant

V.

Americredit Financial Services, INC., Appellee

On Appeal from the 334th District Court

Harris County, Texas

Trial Court Case No. 2008-41513

O P I N I O N

This is a breach of contract case.  The defendant, SLT Dealer Group, LTD d/b/a Alliance Chevrolet (“Alliance”) appeals a final summary judgment granted in favor of the plaintiff, AmeriCredit Financial Services (“AmeriCredit”).  We affirm the trial court’s judgment.  

BACKGROUND

Alliance is an automobile dealer that offers financing to its customers.  When Alliance sells a vehicle under an installment agreement permitting the buyer to make payments over time, Alliance in turn sells that financing contract to a third party.  AmeriCredit is an automobile financing company that purchases these types of individual consumer automobile financing contracts from automotive dealers. 

A.   The Dealer Agreement

On March 24, 2006, Alliance and AmeriCredit entered into a “Dealer Agreement” providing the terms under which AmeriCredit would buy retail installment contracts from Alliance.  The dispute here involves transactions arising under this Dealer Agreement.

In the Dealer Agreement, Alliance made certain representations about each installment contract to be sold to AmeriCredit under the agreement.  These are contained in a section entitled “REPRESENTATIONS, WARRANTIES, AND COVENANTS OF DEALER WITH RESPECT TO EACH CONTRACT,” and include:

The Contract and the Contract Documents will represent a genuine obligation of the Buyer named therein, will be legitimate, valid and binding in accordance with their terms, will be enforceable by AMERICREDIT and its assigned, are free from fraud, and will be subject to no defenses, claims misrepresentations, setoffs or counterclaims of any kind . . . .

The vehicle was sold for the personal use and benefit of the Buyer.

. . . .

No employees or other representatives of Dealer has made any statement or representation to Buyer which conflicts with any terms or provisions contained in the Contract.

At the time of the Contract signing Dealer will complete all forms and documents necessary to perfect a valid and enforceable security interest of AMERICREDIT in the vehicle as required by applicable law and forward and file such forms and documents, together with the appropriate fees, with the public officials responsible for issuing the certificate of title or registration to the vehicle within the earlier of (i) the state law time frame for perfection of AMERICREDIT’s security interest in the vehicle, or (ii) twenty (20) days from the date of the Contract.

The Contract Documents will represent the entire agreement between Dealer and the Buyer with respect thereto and the Contract Documents will not have been modified, superseded, or waived by any act or omission of Dealer. 

B.   The Wallace Contract

On October 4, 2008, Alliance and Gladys Wallace executed a Motor Vehicle Installment Sales Contract (“Wallace Contract”) for the purchase of a 2003 BMW 745I (“Wallace Vehicle”).  Under the Dealer Agreement, Alliance assigned the Wallace Contract to AmeriCredit and received a check for $56,142.83.  As part of this transaction, Alliance sent documents to AmeriCredit that it represented were Wallace’s credit application and tax returns.

After Wallace failed to make her first payment on the car, AmeriCredit investigated and discovered irregularities in the transaction and that the underlying documentation contained false information.  Wallace had never visited Alliance’s dealership.  Victor Holmes, one of Alliance’s employees, had Wallace sign the Wallace Contract at her home.  In exchange for Wallace’s signature on the contract, Holmes paid Wallace $500 cash and represented that she would never have to make a payment on the vehicle.  Wallace’s understanding was that this was an “investment” opportunity, that she was listed as the owner on the contract only “because of [her] credit,” and that the car would be sold to someone else within 30 days.  She never took possession of the car and denied having ever seen the credit application that Alliance submitted to AmeriCredit containing false information about her occupation and income.

Alliance also failed to disclose to AmeriCredit that Alliance secured financing for several other vehicles in Wallace’s name.  Holmes was ultimately fired by Alliance for a number of improprieties, including his involvement in the Wallace deal.            

On March 26, 2007, AmeriCredit made a written demand for Alliance to repurchase the Wallace Contract.  As support, AmeriCredit relied upon the provisions in the Dealer Agreement in which Alliance represented that all financing contracts assigned under the agreement would be “legitimate, valid and binding . . . and free from fraud,” and in which Alliance agreed to repurchase any contract if its obligations were breached.  Alliance did not repurchase the Wallace contract.

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STL Dealer Group, LTD v. Americredit Financial Services, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/stl-dealer-group-ltd-v-americredit-financial-servi-texapp-2011.