Walterine Heard v. Billy Moore, the Pool Company and Pool Energy Services Company

CourtCourt of Appeals of Texas
DecidedMarch 19, 2003
Docket06-02-00151-CV
StatusPublished

This text of Walterine Heard v. Billy Moore, the Pool Company and Pool Energy Services Company (Walterine Heard v. Billy Moore, the Pool Company and Pool Energy Services Company) 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
Walterine Heard v. Billy Moore, the Pool Company and Pool Energy Services Company, (Tex. Ct. App. 2003).

Opinion



In The

Court of Appeals

Sixth Appellate District of Texas at Texarkana



______________________________


No. 06-02-00151-CV
______________________________


WALTERINE HEARD, Appellant


V.


BILLY MOORE, THE POOL COMPANY, AND
POOL ENERGY SERVICES COMPANY, Appellees





On Appeal from the 361st Judicial District Court
Brazos County, Texas
Trial Court No. 50422-361





Before Morriss, C.J., Ross and Carter, JJ.
Opinion by Chief Justice Morriss


O P I N I O N


Walterine Heard appeals a summary judgment granted to Billy Moore, The Pool Company, and Pool Energy Services Company. In two points of error, Heard contends the trial court should not have granted summary judgment in favor of Appellees because (1) res judicata does not apply to parties whose claim was severed from the case on which the final judgment was based, and (2) the trial court received no evidence regarding the accident on which Heard's claim was based.

Factual and Procedural Background

On January 14, 1998, James Ronan Nelson and Moore were involved in an automobile collision. It was alleged that, at the time of the accident, Moore was employed by Pool Energy Services Company or The Pool Company (1) and was driving one of Pool's trucks. Heard was a passenger in Nelson's vehicle.

On December 3,1999, Heard filed suit against Appellees, Moore, The Pool Company, and Pool Energy Services Company, but did not name Nelson as a defendant. Thereafter, Appellees filed a third-party claim for contribution and indemnification against Nelson, contending he was the complete cause of the damages claimed by Heard. Nelson did not file an answer, and on November 9, 2001, the trial court granted a default judgment against him. As part of the default judgment, the trial court concluded that Nelson was negligent and the complete cause of damages, as alleged by the defendants, and thus liable for all damages claimed by Heard in her petition. After the trial court granted the default judgment, Appellees moved to sever their judgment against Nelson from Heard's negligence claim against Appellees. The trial court granted the severance. The default judgment against Nelson became final on December 10, 2001, by operation of law.

After the default judgment against Nelson became final, Appellees moved for summary judgment against Heard based on res judicata. The trial court granted the motion for summary judgment, and Heard appeals. We reverse and remand.

Discussion

Res Judicata

In Heard's first point of error, she contends the trial court erred in granting summary judgment based on res judicata. Specifically, Heard insists that, because her claim was severed from Appellees'  contribution  and  indemnification  claims  against  Nelson,  the  third-party  defendant, res judicata did not bar her from continuing with her suit against Appellees.

The Texas Supreme Court has adopted the transactional approach to res judicata. See Barr v.  Resolution  Trust  Corp.,  837  S.W.2d  627,  631  (Tex.  1992).  Under  the  transactional approach, res judicata precludes relitigation of claims that have been finally adjudicated or that arise out of the same subject matter and that could have been litigated in the prior action between the parties. Amstadt v. United States Brass Corp., 919 S.W.2d 644, 652 (Tex. 1996) (citing Barr, 837 S.W.2d at 628). The policies behind the doctrine are to bring all litigation to an end, prevent vexatious litigation, maintain stability of court decisions, promote judicial economy, and prevent double recovery. See Barr, 837 S.W.2d at 629.

Before explicitly adopting the transactional approach, the Texas Supreme Court also held that, while res judicata precludes litigation of claims on the same cause of action that was or could have been litigated in the first action, a logical corollary to this rule is that res judicata cannot preclude litigation of claims that a trial court explicitly separates or severs from that action. See Van Dyke v. Boswell, O'Toole, Davis & Pickering, 697 S.W.2d 381, 384 (Tex. 1985). Heard's appeal focuses on the distinctions between severed and nonsevered claims.

Appellees, however, insist that the "transactional approach" outlined in Barr trumps the pronouncement in Van Dyke that res judicata cannot preclude litigation of severed claims. Specifically, Appellees point to the Texas Supreme Court's statement in Barr that: "[a] subsequent suit will be barred if it arises out of the same subject matter of a previous suit and which through the exercise of diligence, could have been litigated in a prior suit." Barr, 837 S.W.2d at 631 (emphasis added). Appellees insist that Heard had an obligation to exercise due diligence by either alternatively pleading that Nelson was not completely liable for the collision or, at minimum, object to the trial court's finding that Nelson was completely liable for damages in order for her to avoid claims preclusion under res judicata. Appellees further contend that, because Heard failed to take any action before the default judgment against Nelson became final, she is now barred by res judicata. Our task is to decide to what degree, if any, the transactional approach to res judicata required Heard to dispute Appellees' assertions against Nelson.

Here, Heard chose not to pursue a claim against Nelson. We believe that was her right. It is well established that plaintiffs are the masters of their suit regarding the claims and parties they choose to pursue. See, e.g., Tex. Alcoholic Beverage Comm'n v. Macha, 780 S.W.2d 939, 941 (Tex. App.-Amarillo 1989, writ denied). In addition, Texas Rules of Civil Procedure 38 and 97 outline both the processes and obligations of the parties regarding joinder of claims and third parties. Tex. R. Civ. P. 38, 97. Rule 38(a) allows a defendant to bring third parties into a suit who may be liable for all or part of the plaintiff's damages. See Tex. R. Civ. P. 38(a). Once joined, these third parties, known as third-party defendants, may bring counterclaims against either the defendant or the plaintiff and are subject to the compulsory and permissive counterclaims rules. See Tex. R. Civ. P. 97. Rule 38(a) also outlines the plaintiff's options relating to joined third-party defendants and states, "the plaintiff may

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Walterine Heard v. Billy Moore, the Pool Company and Pool Energy Services Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/walterine-heard-v-billy-moore-the-pool-company-and-pool-energy-services-texapp-2003.