the Island on Lake Travis, Ltd., the Lake Travis Island, Ltd. and the Prime Group, Inc. v. the Hayman Company General Contractors, Inc.

CourtCourt of Appeals of Texas
DecidedJuly 1, 1992
Docket03-91-00409-CV
StatusPublished

This text of the Island on Lake Travis, Ltd., the Lake Travis Island, Ltd. and the Prime Group, Inc. v. the Hayman Company General Contractors, Inc. (the Island on Lake Travis, Ltd., the Lake Travis Island, Ltd. and the Prime Group, Inc. v. the Hayman Company General Contractors, 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.

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the Island on Lake Travis, Ltd., the Lake Travis Island, Ltd. and the Prime Group, Inc. v. the Hayman Company General Contractors, Inc., (Tex. Ct. App. 1992).

Opinion

ISLAND V. HAYMAN
IN THE COURT OF APPEALS, THIRD DISTRICT OF TEXAS,


AT AUSTIN




NO. 3-91-409-CV


THE ISLAND ON LAKE TRAVIS, LTD., ET AL.,



APPELLANTS



vs.


THE HAYMAN COMPANY GENERAL CONTRACTORS, INC.,


APPELLEE





FROM THE DISTRICT COURT OF TRAVIS COUNTY, 98TH JUDICIAL DISTRICT


NO. 462,013, HONORABLE JOE B. DIBRELL, JR., JUDGE PRESIDING




This case involves the arbitration of a construction-contract dispute. A panel of arbitrators of the American Arbitration Association awarded The Hayman Company General Contractors, Inc. ("Hayman Company") the sum of $860,742.31 against The Island On Lake Travis, Ltd. ("The Island"). (1) The Island filed a proceeding in district court seeking to vacate the arbitration award; however, the district court denied The Island's motion to vacate and instead granted Hayman Company's motion to confirm the award. On appeal to this Court, The Island argues that the district court erred in confirming the award because: (1) the arbitrators exceeded their authority; (2) the arbitrators committed gross mistakes of both law and fact; and (3) Hayman Company fraudulently induced The Island to enter into the construction contract. We will affirm the district court's judgment.



BACKGROUND

In August 1986 The Lake Travis Island, Ltd., general partner of The Island On Lake Travis, Ltd., entered into a written contract with Hayman Company for the construction of a condominium project. By early 1987, however, The Island decided to build a retirement center instead of a condominium project; therefore, in September 1987, The Island executed a new construction contract with Hayman Company that reflected the change in the project.

The 1987 agreement provided for the construction of a 212-unit apartment retirement facility for approximately $13 million. Hayman Company was to construct the project on a cost-plus basis with a guaranteed maximum price; in other words, The Island was to pay Hayman Company for its reimbursable costs to the extent such costs, plus a fixed contractor's fee, did not exceed the guaranteed maximum price.

During the course of the construction of the project, a dispute arose concerning, among other things, payments, change orders, and time extensions. This dispute eventually led to Hayman Company's initiating arbitration proceedings against The Island pursuant to the arbitration clause in the construction contract. Hayman Company filed a demand for arbitration with the American Arbitration Association in April 1989, and the Island filed an answer and counterclaim against Hayman Company. The parties engaged in extensive discovery and selected an arbitration panel of three arbitrators. In November 1990, after a three-week hearing, the arbitrators rendered their decision in favor of Hayman Company for $860,742.31.



DISCUSSION

We begin with a brief, general discussion of arbitration. Historically, the settlement of disputes by arbitration has been favored in Texas law. L. H. Lacy Co. v. City of Lubbock, 559 S.W.2d 348, 351 (Tex. 1977); Massey v. Galvan, 822 S.W.2d 309, 316 (Tex. App. 1992, writ denied). Indeed, arbitration has found such favor with Texas courts that we must indulge every reasonable presumption to uphold arbitration awards. Massey, 822 S.W.2d at 316; Carpenter v. North River Ins. Co., 436 S.W.2d 549, 553 (Tex. Civ. App. 1968, writ ref'd n.r.e.).

The law governing arbitration in Texas consists of two coexisting schemes: common-law arbitration and the Texas General Arbitration Act (the "Act"), Tex. Rev. Civ. Stat. Ann. arts. 224 to 238-20 (1973 & Supp. 1992). As stated above, Hayman Company instituted arbitration proceedings against The Island pursuant to the arbitration clause in the written construction contract between the parties; therefore, the present case falls within the realm of the Act. See id. art. 224 (Supp. 1992). However, the legislature did not intend for the Act to supplant common-law arbitration; indeed, if an arbitration award is not within the requirements of the Act, the award may still be valid if it complies with common-law arbitration requirements. L. H. Lacy Co., 559 S.W.2d at 351-52.



1. Exceeding of Authority

As a ground for vacating the arbitration award, The Island argues that the arbitrators exceeded their powers. See Tex. Rev. Civ. Stat. Ann. art. 237, § A(3) (1973). As a basis for its argument, The Island asserts: (1) that Hayman Company assigned the construction contract in question to another general contractor known as Thomas J. Hayman Company ("TJH Company"); and (2) that TJH Company, not Hayman Company, performed the work on the project. Therefore, The Island argues, TJH Company is the real party in interest concerning any disputes under the construction contract, and Hayman Company is without standing to bring any claims under the contract. Based on the foregoing, The Island argues that we must set aside the arbitration award because the arbitrators exceeded their authority by arbitrating claims and giving an award to Hayman Company when TJH Company was the real party in interest concerning disputes under the construction contract.

As stated by the Texas Supreme Court, "the authority of arbitrators is derived from the arbitration agreement and is limited to a decision of the matters submitted therein either expressly or by necessary implication." Gulf Oil Corp. v. Guidry, 327 S.W.2d 406, 408 (Tex. 1959). The construction-contract agreement between Hayman Company and The Island included the following arbitration clause:



All claims, disputes and other matters in question between the Contractor [Hayman Company] and the Owner [The Island] arising out of, or relating to, the Contract Documents or the breach thereof . . . shall be determined by arbitration in accordance with the Construction Industry Arbitration Rules of the American Arbitration Association then obtaining unless the parties mutually agree otherwise. . . . The foregoing agreement to arbitrate and any other agreement to arbitrate with an additional person or persons duly consented to by the parties to the Owner-Contractor Agreement shall be specifically enforceable under the prevailing arbitration law. The award rendered by the arbitrators shall be final, and judgment may be entered upon it in accordance with applicable law in any court having jurisdiction thereof.



As stated above, The Island asserts that Hayman Company assigned the construction contract in question to TJH Company and that TJH Company, not Hayman Company, actually performed on the contract; therefore, any disputes concerning the construction project were actually between The Island and TJH Company, not The Island and Hayman Company.

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Related

House Grain Co. v. Obst
659 S.W.2d 903 (Court of Appeals of Texas, 1983)
L. H. Lacy Co. v. City of Lubbock
559 S.W.2d 348 (Texas Supreme Court, 1977)
Massey v. Galvan Ex Rel. Massey
822 S.W.2d 309 (Court of Appeals of Texas, 1992)
Carpenter v. North River Insurance Company
436 S.W.2d 549 (Court of Appeals of Texas, 1968)
Gulf Oil Corporation v. Guidry
327 S.W.2d 406 (Texas Supreme Court, 1959)
Transwestern Pipeline Co. v. Horizon Oil & Gas Co.
809 S.W.2d 589 (Court of Appeals of Texas, 1991)
Bailey and Williams v. Westfall
727 S.W.2d 86 (Court of Appeals of Texas, 1987)

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the Island on Lake Travis, Ltd., the Lake Travis Island, Ltd. and the Prime Group, Inc. v. the Hayman Company General Contractors, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/the-island-on-lake-travis-ltd-the-lake-travis-isla-texapp-1992.