Thompson v. Anchor Capital GP

CourtTexas Business Court
DecidedMay 4, 2026
Docket25-BC01B-0038
StatusPublished

This text of Thompson v. Anchor Capital GP (Thompson v. Anchor Capital GP) is published on Counsel Stack Legal Research, covering Texas Business Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Thompson v. Anchor Capital GP, (Tex. Super. Ct. 2026).

Opinion

FILED IN BUSINESS COURT OF TEXAS BEVERLY CRUMLEY, CLERK ENTERED 5/4/2026

2026 Tex. Bus. 21

The Business Court of Texas, 1st Division

JEAN CHRISTINE THOMPSON § and THOMPSON PETROLEUM § CORPORATION, Plaintiffs § Cause No. 25-BC01B-0038 § v. § § ANCHOR CAPITAL GP LLC and § MICHAEL MANN, Defendants § ═══════════════════════════════════════ MEMORANDUM OPINION AND ORDER ON PLAINTIFFS’ MOTION FOR SUMMARY JUDGMENT ═══════════════════════════════════════

[¶ 1] This case is about whether defendants breached various contract

duties owed to plaintiffs under a promissory note, security agreement, and

employment agreement. Before the court is Plaintiffs’ Motion for Partial

Summary Judgment. The court considered the parties’ submissions and oral

arguments.

[¶ 2] The pivotal issues are (i) the meaning of the phrase “books and

records” in the Note and Security Agreement; (ii) whether Mann’s alleged unauthorized investments caused a remediable injury; and (iii) whether

Thompson waived the Employment Agreement’s nonwaiver clause and

written prior approval requirement.

[¶ 3] First, the phrase “books and records” is an undefined term. After

applying the applicable law and contract construction principles to the

undisputed facts, the court concludes that the phrase “books and records

relating to the Collateral” broadly encompasses documents related to the

Collateral’s carried interests’ values.

[¶ 4] Second, contract breach claims require some remediable injury.

After reviewing the presented evidence, the court concludes that plaintiffs

failed to conclusively prove that Mann’s alleged unauthorized conduct caused

a remediable injury.

[¶ 5] Third, the court concludes that Mann did not raise a genuine issue

of material fact showing that Thompson waived the Employment Agreement’s

nonwaiver clause. Thus, Thompson Petroleum Corporation conclusively

proved that it had a for-cause basis to fire Mann.

[¶ 6] Accordingly, the court denies-in-part and grants-in-part

plaintiffs’ motion.

MEMORANDUM OPINION AND ORDER, Page 2 I. BACKGROUND

A. Factual Background1

1. The Parties

[¶ 7] Jean Thompson is an owner and President of Thompson

Petroleum Corporation (TPC).2

[¶ 8] TPC is a family business that manages the Thompson family’s

assets and employs the J. Cleo Thompson Family Office’s personnel. 3

[¶ 9] Michael Mann is the founder and CEO of defendant Anchor

Capital GP LLC, a private equity investment brokerage comprised of Anchor

and various subsidiaries.4

[¶ 10] Christy 2017, LP is a holding company for the Thompson

family’s investments. Christy 2017 is not a named party in this case, but it is

a participant in the relevant events.

1 These facts came from evidence contained in the Appendix to Plaintiffs’ Traditional Motion for Partial Summary Judgment (Motion Appx.), which is included in the same document file as Plaintiffs’ Motion, unless otherwise stated. 2 Motion Appx. at 544. 3 Motion Appx. at 544. 4 Motion Appx. at 545.

MEMORANDUM OPINION AND ORDER, Page 3 2. Thompson and Mann form a business relationship.

[¶ 11] Thompson and Mann met in 2022, after which Mann began

offering her investment advice on alternative investments. 5 Using Christy

2017, Thompson then began investing millions into Anchor-managed funds.6

[¶ 12] In September 2024, Mann asked Thompson to loan Anchor

money so he could buy out one of Anchor’s partners.7 She agreed contingent

upon Mann providing a personal financial statement and loan guarantee.8

Mann signed a Secured Promissory Note, Security Agreement, and Mann’s

Personal Guaranty to memorialize this agreement (Loan).9

[¶ 13] The parties amended this agreement three months later after

Mann requested additional funds to buy out another Anchor partner.10

[¶ 14] Based on their existing business relationship, Thompson later

offered Mann employment as the Family Office’s Co-President and Chief

5 Motion Appx. at 545. 6 Motion Appx. at 545. 7 Motion Appx. at 67. 8 Motion Appx. at 546. 9 Motion Appx. at 69–89. 10 Motion Appx. at 547.

MEMORANDUM OPINION AND ORDER, Page 4 Investment Officer.11 Through these roles, Mann was to lead the Family

Office’s alternative investments sector, report solely to Thompson, and join

the “dual authority” group.12 As part of the “dual authority” group, Mann

could initiate and approve wire transfers with another group member’s

approval.13 Mann accepted the employment offer and the parties executed the

Employment Agreement, effective January 1, 2025.14

[¶ 15] Under the Employment Agreement, Mann’s primary duties were

to recruit and build an “alternative investments” team, develop investing

strategy, and originate, close on, and responsibly oversee the company’s

alternative investments. 15 He was also to (i) regularly communicate with

Thompson and Michael Lin (the Family Office’s Chief Legal Officer) and

(ii) ensure Thompson vetted Mann’s investment decisions. 16 Mann was not

11 See Motion Appx. at 109. 12 Motion Appx. at 549–50. 13 Motion Appx. at 549–50. 14 Motion Appx. at 109, 22. 15 Motion Appx. at 123–24. 16 Motion Appx. at 123–24.

MEMORANDUM OPINION AND ORDER, Page 5 allowed to commit any Thompson entity to any new alternative investment

without getting Thompson’s written pre-approval.17

[¶ 16] Mann began work on January 1, 2025. Within a few weeks, he

allegedly committed Christy 2017 to five separate investments. It is

undisputed that Thompson did not give prior written approval for any of these

investments (the Subject Investments).18

[¶ 17] In early February 2025, weeks after Mann signed the first

subscription agreement, Thompson was told about Mann’s investments.19 In

response, she called for weekly in-person meetings between Mann and the

Family Office’s management so the group could track Mann’s activities and

investigate his past actions.20 Mann responded by expressing extreme

frustration and, according to Lin, said he was resigning. 21

17 Motion Appx. at 123. 18 Motion Appx. at 550–52. During oral arguments, defendants asserted that they believed these investments also received written pre-approval from Ms. Thompson, however, they did not request a continuance on this motion nor were they able to point to any evidence suggesting the investments received written pre-approval. 19 Motion Appx. at 552. 20 Motion Appx. at 552–53. 21 See Motion Appx. 369–70, 72, 76.

MEMORANDUM OPINION AND ORDER, Page 6 [¶ 18] On February 28, 2025, Lin and Ted Spence (the Family Office’s

Chief Operating Officer) told Mann that the Family Office was accepting his

resignation offer.22 After Mann denied having offered to resign, Lin responded

by stating Mann was then being terminated for cause due to his Subject

Investments commitments.23 Lin reported Mann’s alleged firing the next

day.24

[¶ 19] On May 5, 2025, Thompson exercised her rights to inspect the

Collateral and verify that her Loan to Anchor was adequately protected.25 To

adequately inspect the Collateral, Thompson asked Anchor to provide access

to its “books and records.”26

[¶ 20] Throughout that month, the parties frequently communicated

about the books and records request.27 But by early June, Thompson claimed

that Anchor failed to produce the requested information. 28 So, on June 16th

22 Motion Appx. at 61–62. 23 Motion Appx. at 61–62. 24 See Motion Appx. 532. 25 Motion Appx. at 378–79. 26 Motion Appx. at 79. 27 See Motion Appx.

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