Universal Underwriters Group v. State

CourtCourt of Appeals of Texas
DecidedJanuary 29, 2009
Docket14-07-00297-CV
StatusPublished

This text of Universal Underwriters Group v. State (Universal Underwriters Group v. State) 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
Universal Underwriters Group v. State, (Tex. Ct. App. 2009).

Opinion

Reversed and Rendered and Majority Opinion filed January 29, 2009

Reversed and Rendered and Majority Opinion filed January 29, 2009.

In The

Fourteenth Court of Appeals

_______________

NO. 14-07-00297-CV

UNIVERSAL UNDERWRITERS GROUP, Appellant

V.

THE STATE OF TEXAS, Appellee

On Appeal from the 208th District Court

Harris County, Texas

Trial Court Cause No. 1089989

M A J O R I T Y   O P I N I O N

The owner of a vehicle appeals the trial court=s order transferring title to the vehicle to the Harris County District Attorney=s Office.  The trial court took this action based on a novel legal theory advanced by the State under article 47.01a of the Texas Code of Criminal Procedure.  We conclude that this legal theory lacks merit under the plain language of the statute.  We reverse and render judgment that the owner is awarded possession of the vehicle without conditions.


                               I. Factual and Procedural Background

On September 14, 2004, Charles Wallace Lovings, a nineteen-year-old male, entered Helfman Dodge (AHelfman@), a car dealership, posing as Phyllis Brocato, a forty-six year old female.  Lovings was dressed in drag when he approached a Helfman salesman.  He presented a driver=s license containing Brocato=s personal information.  Apparently, Lovings had removed Brocato=s photograph and substituted his own image.  Helfman=s salesman obtained two credit reports on Brocato.  Each report prominently stated AInitial Fraud Victim,@ indicating that Brocato previously had been the victim of fraud.  Further, one report indicated that Brocato desired to be contacted before credit was extended in her name.  Nonetheless, Helfman began making arrangements to sell the vehicle.  JP Morgan Chase, a third-party lender, agreed to finance the transaction provided that Helfman verified the AID Bureau Fraud Alert@ and obtained a copy of a government-issued identification card.  The salesman copied the buyer=s identification cards, but no one from Helfman ever contacted Brocato.  Ultimately, JP Morgan Chase extended credit, and Helfman sold a 2006 Chrysler 300, VIN 2C3KA43R96H376552 (Athe vehicle@) to Lovings.

The Houston police arrested Lovings four days later when he attempted to use the same false identification to obtain credit at a different automobile dealership.  On January 31, 2007, Lovings pleaded Aguilty@ to making false statements to obtain credit, and the trial court assessed punishment at four years= confinement.

Following Lovings=s arrest, the vehicle was towed to a private storage lot.  Subsequently, members of Lovings=s family submitted an affidavit of ownership and took possession of the vehicle.  Approximately one month later, the vehicle was impounded by the Houston Police Department.


After discovering Lovings=s fraud, Helfman paid the lender the total amount due under the finance agreement and secured legal title to the vehicle.  After the Harris County District Attorney=s Office refused requests by Helfman for the return of its vehicle, Helfman filed a claim for indemnification with its insurance carrier, appellant Universal Underwriters Group (AUniversal@).  Universal paid Helfman=s claim and thus obtained legal title to the vehicle.

The State later filed a APetition for  Disposition of Stolen Property,@ in which the State sought a hearing under article 47.01a of the Texas Code of Criminal Procedure so that the  trial court could determine which person has the superior right to possession of the vehicle, which the petition indicated might be the Harris County District Attorney=s Office.[1]  Universal claimed it had the superior right to possession because it had paid Helfman=s insurance claim for loss of the vehicle and because it had title to the vehicle.  The State agreed that Universal held title to the vehicle, but the State argued that title is not dispositive of ownership.  Relying on the definition of Aowner@ in the Texas Penal Code, the State asserted what it described as a Avery novel@ legal theory.  Under this theory, if Helfman=s alleged gross negligence made it easier for Lovings to unlawfully appropriate the vehicle, then Helfman forfeits its superior right to possess the property vis-à-vis the district attorney=s office that prosecuted Lovings.[2]  Following a hearing, the trial court accepted this legal theory, found that the Harris County District Attorney=s Office has the superior right to possession of the vehicle, and ordered that title to the vehicle be transferred to the Harris County District Attorney=s Office.  In this appeal, Universal challenges the trial court=s order.

II. Issue and Analysis


In its second issue, Universal asserts that the trial court erred as a matter of law in finding that the Harris County District Attorney=s Office has the superior right to possession of the vehicle and in ordering that title to the vehicle be transferred to the Harris County District Attorney=s Office.[3]  Under article 47.01a, the State may petition the district court to hold a hearing to determine who has the superior right to possession of the vehicle.  See Tex. Code Crim. Proc. Ann. art.

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Glasscock v. First National Bank
266 S.W. 393 (Texas Supreme Court, 1924)
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Bluebook (online)
Universal Underwriters Group v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/universal-underwriters-group-v-state-texapp-2009.