TWC Aviation, Inc. D/B/A Landmark Aircraft Management & Charter-SJC v. World Tech Aviation, LLC

CourtCourt of Appeals of Texas
DecidedDecember 31, 2024
Docket01-23-00079-CV
StatusPublished

This text of TWC Aviation, Inc. D/B/A Landmark Aircraft Management & Charter-SJC v. World Tech Aviation, LLC (TWC Aviation, Inc. D/B/A Landmark Aircraft Management & Charter-SJC v. World Tech Aviation, LLC) 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
TWC Aviation, Inc. D/B/A Landmark Aircraft Management & Charter-SJC v. World Tech Aviation, LLC, (Tex. Ct. App. 2024).

Opinion

Opinion issued December 31, 2024

In The

Court of Appeals For The

First District of Texas ———————————— NO. 01-23-00079-CV ——————————— TWC AVIATION, INC. D/B/A LANDMARK AIRCRAFT MANAGEMENT & CHARTER – SJC, Appellant V. WORLD TECH AVIATION, LLC, Appellee

On Appeal from the 215th District Court Harris County, Texas Trial Court Case No. 2017-33283-7

OPINION

Appellant, TWC Aviation, Inc., doing business as Landmark Aircraft

Management & Charter – SJC (“Manager”),1 challenges the trial court’s judgment,

1 On January 1, 2017, TWC Aviation, Inc., doing business as Landmark Aircraft Management & Charter – SJC, was purchased by GAMA Aviation, LLC entered after a bench trial, in favor of appellee, World Tech Aviation, LLC (“World

Tech”), in World Tech’s suit against Manager for breach of contract, conversion,

and violation of the fraudulent lien statute and Manager’s countersuit against World

Tech for breach of contract and foreclosure of its lien. In four issues, Manager

contends that trial court erred in granting World Tech’s motion for partial summary

judgment and declaring that Manager did not possess a valid lien on the aircraft; the

evidence is legally insufficient to support the trial court’s findings that Manager’s

actions caused World Tech actual damages and that Manager was liable for

conversion and violation of the fraudulent lien statute; and the evidence conclusively

established that Manager was entitled to recover on its breach-of-contract

counterclaim against World Tech.

We affirm in part, reverse in part, render in part, and remand in part.

Background

World Tech entered an aircraft services agreement (the “services agreement”)

with Manager in April 2016, under which Manager agreed to manage certain

maintenance tasks on World Tech’s aircraft in exchange for World Tech’s payment

of a management fee and reimbursement of maintenance, fuel, and other operational

(“GAMA”). This change of ownership is not relevant to the legal issues raised in this appeal. For consistency and ease of reference, we will refer to both TWC Aviation, Inc., doing business as Landmark Aircraft Management & Charter – SJC, and GAMA as “Manager.”

2 costs. Manager agreed to send World Tech a monthly “itemized statement of [its]

account,” showing the fees that World Tech had incurred “through the end” of the

“prior calendar month.” World Tech, in turn, was required “pay to [Manager] an

amount equal” to any “net debit balance” reflected on the account “within thirty (30)

days” of its receipt of an “itemized statement.” If World Tech disputed “any of the

charges listed on a particular statement,” it was required to:

(i) promptly notify [Manager] of such dispute; (ii) pay undisputed amounts within thirty (30) days of receipt of such itemized statement; and (ii[i]) negotiate a resolution of the dispute with [Manager] as soon as possible, but no later than ten (10) [b]usiness [d]ays after the expiration of the thirty (30) day period in which to pay undisputed amounts.

If any payment owed on World Tech’s account was past due, Manager “reserve[d]

the right, upon notice to client, to temporarily suspend any and all services” that it

owed World Tech under the services agreement.

In a separate paragraph, entitled “Breach of Payment Obligations,” the

services agreement further declared that:

[F]ailure to pay any sum due to [Manager] within ten (10) days of the due date shall be a breach of contract. In the event of such breach, [Manager] shall not be obligated to provide more than one (1) notice of breach during any twelve (12) month period for any instance of [World Tech] failing to pay any amount, when due, to [Manager]. All sums past due will bear interest of (1.5%) per month (or the maximum amount allowed by applicable law), plus [World Tech] shall be liable for all reasonable attorney fees, and other costs of collection.

3 If the parties otherwise terminated the services agreement, Manager was to send

World Tech “a final itemized accounting statement of all [c]harter fees, [c]osts and

[e]xpenses, [o]perating [c]osts, [i]ncidental [e]xpenses, and [h]angar [f]ees” within

sixty days after termination. “Payment of any net balance or net credit balance

indicated in such final statement [was to] be paid by the owing party to the other

party within ten (10) days of the date of the final itemized accounting statement.”

World Tech was also entitled to a refund of its deposit at termination, “[s]o long as

(i) no event of default exist[ed], (ii) Manager [was] paid in full, and (iii) such

[d]eposit ha[d] not already been applied to amounts due from [World Tech] under

th[e] [services] [a]greement.”

Manager and World Tech also executed a charter and lease agreement, under

which World Tech agreed to “[d]ry [l]ease[2] the aircraft to Manager and Manager

agreed to [d]ry [l]ease the [a]ircraft from [World Tech].” Under the charter and lease

agreement, Manager had the right to “use and operate the [a]ircraft to conduct

[charter] [o]perations from time to time when the [a]ircraft [wa]s not otherwise in

use by [World Tech].” The arrangement contemplated that World Tech would

schedule its own use of the aircraft, and Manager would schedule use of the aircraft

2 See 14 C.F.R. § 91.1001(b)(2) (“A dry-lease aircraft exchange means an arrangement, documented by the written program agreements, under which the program aircraft are available, on an as needed basis without crew, to each fractional owner.”).

4 for charter flights so that the times scheduled for use did not conflict. The charter

and lease agreement also provided that World Tech would be paid “$3,570[] per

actual flight hour” of a charter operation, a fee that could be adjusted by Manager,

with World Tech’s approval, “based upon market conditions.”

The charter and lease agreement also specified other financial conditions. As

to charter flights, the agreement made clear that World Tech was not involved in,

and Manager was “solely responsible for[,] billing and collecting payment from

[c]harter [c]ustomers” as well was for handling charges and reimbursements “for

catering, customs, ground transportation,” and other fees associated with the charter

flights. As to World Tech’s use of the aircraft, the charter and lease agreement

specified that “[a]ll [o]perating [c]osts and [i]ncidental [e]xpenses incurred by

[Manager]” on behalf of World Tech would be “charged to [World Tech’s] account.”

The services agreement and the charter and lease agreement both contained

choice-of-law provisions reciting that the agreements were “negotiated and

delivered in the State of Texas” and would “in all respects be governed by, and

construed in accordance with, the laws of the State of Texas, including all matters

of construction, validity, and performance, without giving effect to its conflict of

laws provisions.” Both agreements also contained “no waiver” provisions stating

that:

No delay or omission in the exercise or enforcement of any right or remedy hereunder by either party shall be construed as a waiver of such 5 right or remedy. All remedies, rights, undertakings, obligations, and agreements contained herein shall be cumulative and not mutually exclusive, and in addition to all other rights and remedies which either party possesses at law or in equity.

In its amended petition, World Tech alleged that under its agreements with

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TWC Aviation, Inc. D/B/A Landmark Aircraft Management & Charter-SJC v. World Tech Aviation, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/twc-aviation-inc-dba-landmark-aircraft-management-charter-sjc-v-texapp-2024.