Sun Development, L.P. v. Larry Hughes and Susan Hughes

CourtCourt of Appeals of Texas
DecidedSeptember 25, 2014
Docket09-12-00524-CV
StatusPublished

This text of Sun Development, L.P. v. Larry Hughes and Susan Hughes (Sun Development, L.P. v. Larry Hughes and Susan Hughes) 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
Sun Development, L.P. v. Larry Hughes and Susan Hughes, (Tex. Ct. App. 2014).

Opinion

In The

Court of Appeals Ninth District of Texas at Beaumont ____________________

NO. 09-12-00524-CV ____________________

SUN DEVELOPMENT, L.P., Appellant

V.

LARRY HUGHES AND SUSAN HUGHES, Appellees _________________________________ ______________________

On Appeal from the 9th District Court Montgomery County, Texas Trial Cause No. 09-10-10214 CV ____________________________________________ ____________

MEMORANDUM OPINION

This appeal arises from the trial of a case that relates to Sun Development,

L.P.’s sale of a new home to Larry and Susan Hughes. After they purchased the

home, the Hugheses learned the home needed significant repairs. They then sued

Sun, alleging that Sun had breached the parties’ agreements and had engaged in

deceptive trade practices regarding the sale. At the conclusion of a jury trial, the

jury found that Sun had engaged in a deceptive trade practice, and that Sun had

1 breached a Rule 11 1 agreement, which obligated Sun to do several things in return

for the Hugheses decision to exercise an option Sun gave them in return for closing

on the home. After the trial, the Hugheses elected to recover judgment against Sun

under the jury’s DTPA findings, as those findings allowed the Hugheses a greater

recovery.

In eight issues, Sun appeals from the trial court’s judgment. We agree with

Sun’s argument in its first issue, and hold that the trial court’s decision to deny

Sun’s request to identify the entity that installed the stucco on the home as a

responsible third party was error, and we further conclude that the error was

harmful. We reverse the trial court’s judgment, and we remand the cause for a new

trial.

Factual and Procedural Background

After the Hugheses signed a contract to purchase the home, they identified

several items that Sun agreed to complete or repair before the date the parties

selected to close on the sale. Before the closing date arrived, a dispute arose

regarding whether Sun had completed its work. Claiming that all of the items had

been substantially repaired, Sun filed a suit for declaratory judgment against the 1 Rule 11 of the Texas Rules of Civil Procedure requires agreements touching “any suit pending” to be in writing, signed, and filed with the papers as part of the record or made in open court to make such agreements enforceable. Tex. R. Civ. P. 11. 2 Hugheses in Galveston. In its suit, Sun asked the court to declare the rights of the

parties under the agreements relating to the home’s sale. To resolve the declaratory

judgment suit, the Hugheses and Sun signed a letter of agreement in 2008 that gave

the Hugheses two alternatives, the right to inspect and close on the home, or the

right to cancel their agreement to buy the home. The Rule 11 agreement gave the

Hugheses several days after they signed the agreement to inspect the home and

decide which of the options they wanted to exercise.

In August 2008, the Hugheses opted under the agreement to close on the

home. Under the Rule 11 agreement, given the Hugheses’ decision to purchase the

home, Sun’s builder and Sun were obligated to perform several future acts. For

instance, Sun’s builder was required to take “care of normal and customary punch

list items.” Sun was obligated to provide the Hugheses with a “2-10 warranty[,]” to

pay the Hugheses $15,000 at closing, and to give them a $12,000 credit for

landscaping and irrigation. Sun also agreed in the Rule 11 agreement that it would

dismiss its declaratory judgment action, and both parties agreed they would

execute mutual releases, which waived “any and all known causes of action that

either party could assert against the other arising from the home purchase

transaction.”

3 Had the Hugheses opted to cancel the sale, the Rule 11 agreement would

have required that Sun return the earnest money the Hugheses had paid on the

home, that Sun pay the Hugheses $45,000 for the expenses the Hugheses incurred

for items they had “purchased and used at the home[,]”and that Sun dismiss its suit

for declaratory judgment. Had the cancellation option been selected, the Rule 11

agreement still required both parties to execute mutual releases.

Approximately three months after closing on the home, the Hugheses hired

Lynn DeGeorge, a general contractor, consultant, and inspector to inspect the

stucco system on their home. DeGeorge holds certifications specific to inspecting

homes that are clad in stucco. Although the Hugheses had benefitted from several

inspections by inspectors who examined the home before they exercised the option

they were given in the Rule 11 to close on the home, none of the inspectors the

Hugheses utilized before they closed held certifications specific to inspecting

stucco. DeGeorge advised the Hugheses that the stucco on the home needed

extensive repair.

In 2009, the Hugheses filed suit against Sun, claiming that Sun had engaged

in deceptive trade practices in selling the home and that Sun had breached several

terms of the parties’ Rule 11 agreement that related to the purchase. The Hugheses’

live pleading at the time of the trial, their fourth amended petition, alleges that Sun

4 knowingly failed to disclose information concerning the home’s construction with

the intent to induce them to purchase the home. The Hugheses also alleged that

they would not have purchased the home had Sun fully disclosed information

about the home that Sun knew about before the sale closed.

The case was tried to a jury in April 2012. At the conclusion of the trial, the

jury found that Sun failed to disclose “information concerning construction

services that was known at the time of the transaction with the intention to induce

[the Hugheses] into a transaction they otherwise would not have entered into if the

information had been disclosed.” On appeal, Sun argues that no evidence before

the jury shows that it knew, on the date the sale closed, of any problems that it did

not disclose. Additionally, Sun argues that the Hugheses relied solely on their own

inspections when they closed on the sale, and it argues that the Hugheses did not

rely on any of the information that it gave them when they finally decided they

wanted to close on the home.

During the trial, the respective home inspection reports obtained by the

Hugheses and Sun were admitted into evidence. The reports that each of the parties

received are evidentiary of what the parties knew regarding both the type and

scope of repairs the home needed at various times as the parties negotiated whether

the sale would close. The various reports and bids that Sun received from its

5 inspector and from its contractors were also relevant to the jury’s evaluation of

whether Sun fully disclosed all it knew about the scope of repairs needed to the

stucco on the home.

We will first address the reports the Hugheses obtained from the inspectors

they hired. The Hugheses had the benefit of reports from three inspectors who had

looked at the home at various times before the sale closed. In 2007, Gordon Guffin

inspected the home. Guffin gave the Hugheses a written report regarding his

inspection, and his report identified several exterior and interior construction

problems that needed to be addressed. The problems that Guffin reported include

indoor and outdoor water leaks at various specific locations. The types of problems

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