Texas Hauling Contractors Corp. v. Rose Sales Co.

565 S.W.2d 240
CourtCourt of Appeals of Texas
DecidedMarch 31, 1978
Docket1259
StatusPublished
Cited by11 cases

This text of 565 S.W.2d 240 (Texas Hauling Contractors Corp. v. Rose Sales Co.) 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
Texas Hauling Contractors Corp. v. Rose Sales Co., 565 S.W.2d 240 (Tex. Ct. App. 1978).

Opinions

OPINION ON MOTION

PER CURIAM.

The question of proper authentication and resolution of objections to the statement of facts is before this Court in various postures in three different appeals now pending in this Court. The question presented in Cause Number 1259, “Texas Hauling Contractors Corp. v. Rose Sales Company”, is the same as the question in Cause Number 1255, “Nueces Trust Company v. Carlos T. (Buddy) White”, and the remedy is also applicable in Cause Number 1286, “Gaudalupe S. Farias v. Texas General Indemnity.”

The appellants in Causes 1259 and 1255 timely presented statements of fact for filing in their respective appeals. In each case, the statement of facts was signed by the trial judge but not by counsel for appellant or appellee. On appeal, the respective appellees have filed motions to strike the statements of fact, contending that Rule 377(d), T.R.C.P., does not permit authentication by the trial judge unless the parties are unable to agree on the correctness of the statement of facts and have presented the document to the judge so that he might settle the differences and make the statement of facts conform to the truth.

Rule 377(d) provides:
“It shall be unnecessary for the statement of facts to be approved by the trial court or judge thereof when agreed to by the parties. If any difference arises as to whether the record truly discloses what occurred in the trial court, or if the op[242]*242posing party fails to agree or to disagree within ten days after being furnished with a copy of the proposed statement of facts, the matter shall be submitted to and settled by the trial court or judge thereof and the statement of facts be by him made to conform to the truth.”

The rule states that it is “unnecessary” to secure the approval of the trial judge unless, the parties fail or refuse to agree on the statement of facts, but it does not state that it is improper to secure the approval of the trial judge in other circumstances. The question, therefore, is whether the trial judge’s signature on the statement of facts constitutes a valid authentication.

Authentication is an informality which can be waived under Rule 404, T.R.C.P., if no objection is made within 30 days. Roberson Farm Equipment Company v. Hill, 514 S.W.2d 796 (Tex.Civ.App.—Texarkana 1973, writ ref’d n. r. e.); Sparks v. Chandler, 201 S.W.2d 252 (Tex.Civ.App.—El Paso 1947, no writ). Since objections were raised by the appellees in Causes 1255 and 1259 within 30 days of the filing of the statements of fact, no waiver has occurred in these two cases.

The courts have not been entirely consistent in their approach to authentication under Rule 377(d). Approval by the trial judge without prior presentation of the statement of facts to appellee has been considered sufficient compliance with Rule 377(d) to serve all the purposes contemplated by the rule. Wells-Grinnan M.A.B. v. Belton Sand and Gravel Co., 293 S.W.2d 70 (Tex.Civ.App.—Austin 1956, no writ); Newsom v. Boyd, 203 S.W.2d 874 (Tex.Civ.App.—Galveston 1947, no writ); Sparks v. Chandler, supra. In Sparks the court stated:

“Section (d) contemplates, we think, that the statement of facts when prepared will be submitted to the opposing party for action thereon, but there is no provision that does in anywise condemn one prepared, certified and approved as a full and complete and true statement of the facts adduced on the trial.”

As an additional reason to permit filing of the statement of facts, the court in Sparks cited waiver under Rule 404 due to lateness of the motion to strike. In Wells-Grinnan and Newsom, however, there was no indication that the objections were tardy.

In contrast, the Ft. Worth Court viewed a statement of facts signed by a judge as “incomplete” because it contained no certificate showing the necessity for the judge’s approval. Foster v. Buchele, 213 S.W.2d 738 (Tex.Civ.App.—Ft. Worth 1948, writ ref’d n. r. e.). In Foster, the appellee’s motion to strike the statement of facts contained numerous objections to purported errors and omissions. Rather than striking the statement of facts or filing it as presented, the Court granted the parties 15 days in which to reach an agreement. If no agreement was achieved in the allotted time, then the parties to the appeal were to follow the procedures in Rule 377(d) in seeking authentication by the trial judge.

The Beaumont Court in St. Paul Fire & Marine Insurance Company v. Lake Livingston Properties, Inc., 546 S.W.2d 404 (Tex.Civ.App.—Beaumont 1977, writ ref’d n. r. e.), struck the statement of facts and held that a statement of facts signed only by the court reporter and judge to be “unauthenticated.” We believe that this result is too harsh and is not called for by the Rules of Civil Procedure or the prior case law.

We agree with the reasoning in Roberson Farm Equipment Company v. Hill, supra. The opinion clearly and correctly states the law in regard to the need for authentication and the circumstances under which it can be waived. In Roberson, neither the trial judge nor the parties had signed the statement of facts. We find nothing in the opinion which expressed a need or even a preference for first seeking the approval of the parties before presenting the statement of facts to the judge. Neither Roberson nor Rule 377(d) requires such a severe penalty as striking the statement of facts when the same has been submitted to the judge for approval rather than the parties or their attorneys. Wells-Grinnan M.A.B. v. Belton Sand and Gravel Co., supra.

[243]*243The clear intent of Rule 377(d) is to avoid the necessity of asking judges to review statements of fact except in instances where a disagreement between the parties needs to be resolved. We believe that attorneys should be encouraged to follow this procedure. However when time or circumstances seems to require the prior approval by the trial judge, we see no need for enforcing strong sanctions against the appellant just because the parties do not approve the statement of facts prior to filing in the appellate court. We therefore adopt an approach to the problem similar to that outlined. in Foster v. Buchele, supra. Where, as in the situations here presented, there is a question of proper authentication of the statement of facts, and an objection to the statement of facts is made within 30 days after the same is filed in a Court of Civil Appeals, the objecting parties may request a reasonable time in which to approve the statement of facts or present his objection to the opposing party for his approval to the objected matter. Where resolution of the differences cannot be had between the parties, then such disagreements shall be submitted to the trial judge for his resolution based on his own recollections as rule 377(d) envisions. If any material matter has been omitted or it is shown that the statement of facts was prepared in violation of the rules, remedial action under Rules 428 and 429, T.R.C.P., is available.

In Cause 1286, a different type of objection to the statement of facts was raised, but the remedy is similar to that prescribed above.

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Texas Hauling Contractors Corp. v. Rose Sales Co.
565 S.W.2d 240 (Court of Appeals of Texas, 1978)

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565 S.W.2d 240, Counsel Stack Legal Research, https://law.counselstack.com/opinion/texas-hauling-contractors-corp-v-rose-sales-co-texapp-1978.