the Landing Council of Co-Owners v. James B. Durham and Mary Lou Durham

CourtCourt of Appeals of Texas
DecidedNovember 20, 2007
Docket14-06-00417-CV
StatusPublished

This text of the Landing Council of Co-Owners v. James B. Durham and Mary Lou Durham (the Landing Council of Co-Owners v. James B. Durham and Mary Lou Durham) 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 Landing Council of Co-Owners v. James B. Durham and Mary Lou Durham, (Tex. Ct. App. 2007).

Opinion

Affirmed as Modified and Opinion filed November 20, 2007

Affirmed as Modified and Opinion filed November 20, 2007.

In The

Fourteenth Court of Appeals

_______________

NO. 14-06-00417-CV

THE LANDING COUNCIL OF CO-OWNERS, Appellant

V.

JAMES B. DURHAM AND MARY LOU DURHAM, Appellees

On Appeal from County Civil Court at Law No. 2

Harris County, Texas

Trial Court Cause No. 806,325

O P I N I O N


Appellant, The Landing Council of Co-Owners (Athe Council@), appeals the portion of a judgment in favor of appellees, James B. Durham and Mary Lou Durham (collectively Athe Durhams@), awarding exemplary damages on their Deceptive Trade Practices Act  (ADTPA@) claim.  In seven issues, the Council contends the Durhams lacked Aconsumer@ status, and the evidence is legally and factually sufficient to support the jury=s findings that the Council committed a Afalse, misleading, or deceptive act or practice@ and engaged in the conduct Aknowingly.@  We conclude the evidence is legally insufficient to support the jury=s finding that the Council knowingly committed a false, misleading, or deceptive act or practice.  Accordingly, we modify the trial court=s judgment to delete the award of exemplary damages and affirm as modified.

I.  Background

The Council governs a condominium complex known as AThe Landing@ through a written ACondominium Declaration@ (Athe Declaration@).  The Durhams own several units in the complex.  In 1993, they purchased unit number 338, which is the subject of this suit.  Before the purchase, the Durhams learned of a structural problem with the floor of this unit.  The Council made repairs before the purchase was completed.  In February 2003, the Durhams= long-time lessees vacated the unit.  While preparing to relet, the Durhams discovered several large cracks in a concrete patch in the area of the floor that was repaired before they purchased the unit.

Under the Declaration, responsibilities for various aspects of maintenance are divided between the Council and a unit owner as follows, in pertinent part:

1.         By the Council.  The Council shall maintain, repair, and replace, as a common expense of the Council:

a.    All portions of a Unit, except interior surfaces, contributing to the support of the Buildings, which portions shall include but not be limited to the outside walls of the Buildings and all fixtures on the exterior thereof, boundary walls of Units, floor and ceiling slabs, load-bearing columns, and load-bearing walls.

. . .

2.       By Each Co-Owner.  The responsibility of a Co-Owner shall be as follows:

a.    To maintain, repair, and replace at his expense all portions of his Unit, except the portions to be maintained, repaired, and replaced as a common expense. . . .


According to the Durhams, under this provision, the Council was obligated to repair their floor.  Mrs. Durham immediately notified the Council regarding the problem and requested the repair.  She was informed that the Council=s attorney would review the Declaration to determine the extent of its obligations.  Over the following months, Mrs. Durham and her attorney repeatedly contacted the Council attempting to obtain a response to the Durhams= request.  Many of these communications went unanswered.  However, the Council effectively informed the Durhams the repair was their responsibility because there was no Astructural@ defect in their floor.  According to the Council, it is obligated under the Declaration to repair only Astructural@ problems, while the owner must remedy Acosmetic@ defects.  After a Council board representative and its maintenance supervisor viewed the floor, the Council decided the problem was cosmetic because it involved a Abad patch job.@

Eventually, the Durhams sued the Council for breach of contract, negligence, breach of fiduciary duty, and DTPA violation.  Subsequently, in an effort to resolve the matter, the Council offered to repair the floor, while still denying any obligation to do so.  The record is unclear regarding the reason the Durhams did not accept this offer.  Nevertheless, the floor remained unrepaired at the time of trialCalmost three years after the Durhams discovered the problem.[1]  The Durhams claimed they were unable to relet the unit absent the repair.


A jury found in the Durhams= favor on the three theories of liability submitted in the charge: breach of contract, breach of fiduciary duty, and DTPA violation.  With respect to the DTPA claim, the jury found the Durhams were Aa consumer,@ the Council committed Aa false, misleading, or deceptive act or practice,@ and it engaged in this conduct Aknowingly.@  The judgment reflects the Durhams elected recovery on the DTPA claim.  The trial court entered judgment awarding the Durhams $42,500 in actual damages, representing loss of rental income, $20,000 in exemplary damages, attorney=s fees, and interest.

II.  The Issues and Our Review

Preliminarily, we note the Council seeks reversal of only the exemplary-damages award.[2]  The Durhams were awarded exemplary damages based on the jury=

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