the Cadle Company v. James Morgan

CourtCourt of Appeals of Texas
DecidedApril 14, 2005
Docket01-03-01020-CV
StatusPublished

This text of the Cadle Company v. James Morgan (the Cadle Company v. James Morgan) 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
the Cadle Company v. James Morgan, (Tex. Ct. App. 2005).

Opinion

Opinion issued April 14, 2005



In The

Court of Appeals

For The

First District of Texas





NO. 01-03-01020-CV





THE CADLE COMPANY, Appellant


V.


JAMES L. MORGAN, Appellee





On Appeal from the 333rd District Court

Harris County, Texas

Trial Court Cause No. 2003-07378





MEMORANDUM OPINION

          The issue in this case is whether the Cadle Company [“Cadle”] is bound by a settlement negotiated by its outside counsel, Brett Lanier, with a judgment debtor, James Morgan. In five related issues on appeal, Cadle contends the trial court erred in finding that Lanier possessed the authority, either actual or apparent, to negotiate the settlement with Morgan. In a sixth issue, Cadle challenges the damages awarded to Morgan.

          BACKGROUND

          In November 1987, Park 45 National Banks obtained a default judgment against Morgan in the amount of $31,355.10, plus $5,265 in attorneys fees. In 1990, Cadle purchased the right to the default judgment from the FDIC.

          In 1992, 1995, and 1996, Cadle employees sent Morgan a series of letters offering to settle the default judgment for a percentage of the $34,907.10 that the letters claimed was now owed on the judgment. In 1999, after Cadle’s attempts to settle the claim with Morgan failed, a Cadle employee called Morgan and told him to expect to hear from Cadle’s attorney regarding the default judgment claim.

          In March 2001, Laura Harkless, a Cadle employee who was responsible for retaining and supervising outside counsel to assist in Cadle’s debt collecting efforts, hired Brett Lanier to collect Morgan’s debt. Harkless obtained Lanier’s name from a book entitled Bankers Collection Lawyers. Harkless had never met Lanier, Cadle had never done business with Lanier, and Harkless did not check any of Lanier’s references before hiring him.

          After hiring Lanier, Harkless sent him certain confidential information relating to the collection of the Morgan debt. Thereafter, Harkless did not have any contact with Lanier, even though Cadle’s own rules for supervising outside counsel require that outside counsel provide written status reports on their case every 60 days. Harkless testified that she tried to call Lanier several times, but was unable to reach him because his telephone had been disconnected.

          Harkless was aware that Lanier’s telephone had been disconnected and that she had no way to contact him, but she never relayed this information to Morgan or his attorney even though she knew Morgan’s telephone number and had spoken with him previously.

          In February and March of 2002, Lanier contacted Morgan regarding the collection of the default judgment. Morgan told Lanier to contact his attorney, Michael Landrum. On March 18, 2002, Lanier sent a letter to Landrum, in which Lanier stated, “My client is now calling me every day. I have some settlement authority, but only if Mr. Morgan acts quickly.” Lanier communicated an offer to settle the judgment for $20,000. When Morgan countered at $15,000, Lanier confirmed to Landrum that the judgment would be settled when Morgan made a $15,000 wire transfer to Lanier’s account for Cadle, which Morgan did.

          A few months after Morgan paid Lanier, Morgan received a telephone call from Harkless regarding the money he owed Cadle. Morgan told Harkless that he did not owe Cadle, and then Harkless asked Morgan if he knew how she could get in touch with Lanier, her own attorney.

          After learning of the settlement from Morgan, Harkless sent two letters to Lanier demanding that he turn over the settlement funds immediately. In neither letter did Harkless claim that the settlement was unauthorized; she simply demanded that Lanier give the money to Cadle.

          In February 2003, Harkless, on Cadle’s behalf, filed an application with the Texas State Bar Client Security Fund claiming that it had lost $70,038.41, the entire amount of the default judgment, because of Lanier’s conduct. Harkless admitted that the only way Cadle could have lost the entire value of the default judgment was if Lanier had settled that claim.

          Morgan filed suit against Cadle seeking declaratory and injunctive relief, as well as damages, contending that Cadle was bound by the settlement entered into by Morgan and Lanier, Cadle’s outside counsel. After a bench trial, the trial court found in favor of Morgan and entered a judgment that (1) declared that Cadle’s judgment against Morgan was “fully and finally released”; (2) permanently enjoined Cadle from making any efforts to collect on the judgment; (3) ordered Cadle to release any and all liens attached to Morgan’s property; and (4) awarded damages to Morgan.

                                                          AGENCY

          In its first issue, Cadle contends that “Lanier lacked actual authority to bind the Cadle Company to a settlement.” In its second issue, Cadle contends that Lanier did not have the apparent authority to bind Cadle to a settlement. Although Cadle does not specify a standard of review in either of these issues, we will construe its first two issue as challenges to the legal and factual sufficiency of the evidence to support the trial court’s finding that “Lanier had authority (actual and apparent) to bind Cadle to the Settlement Agreement.” More specifically, the question is this, “Was Lanier acting as Cadle’s agent when he negotiated the settlement agreement with Morgan?”

          A principal is liable for the acts of its agent when the agent has actual or apparent authority to do those acts or when the principal ratifies those acts. Spring Garden 76U, Inc. v. Stewert Title Co., 874 S.W.2d 945, 948 (Tex. App.—Houston [1st Dist.] 1994, no writ); see Currey v. Lone Star Steel Co., 676 S.W.2d 205, 209 (Tex. App.—Fort Worth 1984, no writ) (actual and apparent authority); Little v. Clark, 592 S.W.2d 61, 64 (Tex. Civ. App.—Fort Worth 1979, writ ref’d n.r.e.) (ratification).

Actual Authority

          

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